Aerial application is one of the oldest commercial uses of aircraft in America, and it has its own corner of the Federal Aviation Regulations: 14 CFR Part 137 — Agricultural Aircraft Operations. A crop-dusting outfit, an aerial-seeding contractor, or a forestry-treatment operator does not fly on a Part 135 charter certificate — it flies on a Part 137 agricultural aircraft operator certificate, a distinct operating authorization with its own certification, personnel, equipment, and recordkeeping rules.
That distinction matters because the compliance objects are different. Part 137 is light on the kind of voluminous maintenance-program recordkeeping that defines larger Part 135 operations, but it is exacting about three things: who is allowed to hold the certificate, what knowledge and skill the operator and its pilots must demonstrate, and a short, specific set of dispensing records a commercial operator must keep. Get those three right and the rest of Part 137 is operating discipline.
This guide walks the certificate (§137.19), the knowledge and skill tests (§137.19(e)), carrying the certificate (§137.33), and the records a commercial operator must maintain (§137.71) — and clears up two section numbers operators routinely misremember.
What Part 137 Covers — and What an "Agricultural Aircraft Operation" Is
Part 137 prescribes the rules for agricultural aircraft operations in the United States and for the issuance of two certificate types — private and commercial agricultural aircraft operator certificates (§137.1). The trigger is the definition of an agricultural aircraft operation in §137.3.
§137.3 — "Agricultural aircraft operation" means operating an aircraft for the purpose of:
- Dispensing any economic poison (the §137.3 term for pesticides, herbicides, and similar substances declared a pest control agent);
- Dispensing any other substance intended for plant nourishment, soil treatment, propagation of plant life, or pest control; or
- Engaging in dispensing activities directly affecting agriculture, horticulture, or forest preservation — but not including the dispensing of live insects.
The live-insect carve-out matters: dispensing beneficial insects (for biological pest control) is excluded from the §137.3 definition and therefore from the Part 137 certificate requirement.
The split between private and commercial certificates is built into §137.19(a). A private agricultural aircraft operator certificate applicant must comply with §137.19 paragraphs (b), (d), and (e); a commercial applicant must comply with (c), (d), and (e). The practical difference is that a commercial operator dispenses for others, while a private operator dispenses on land it owns, leases, or rents in connection with its own farming or forestry. The recordkeeping rule we cover below, §137.71, is written specifically for the commercial certificate holder.
Part 137 is a separate certificate — not a flavor of Part 135
Aerial application is not air-carrier or charter flying, and Part 137 is not a subset of Part 135. The certificates, the certification gates, and the records are different. An operator that also conducts charter would hold both certificates and keep both record sets — the Part 137 dispensing records under §137.71 and, separately, the Part 135 operator records and Part 135 pilot records. Mixing the two regimes in one filing cabinet is a common source of "we thought that was covered" gaps.
The Agricultural Aircraft Operator Certificate — 14 CFR §137.19
§137.19 (Certification requirements) sets the substantive gates for issuance. Three things have to be true: a properly rated pilot, an airworthy and properly equipped aircraft, and a demonstration of knowledge and skill.
§137.19(b) / (c) — The Pilot-Certificate Floor
For a private certificate, §137.19(b) requires the applicant to hold a current U.S. private, commercial, or airline transport pilot certificate and be properly rated for the aircraft to be used. For a commercial certificate, §137.19(c) requires the applicant to have available the services of at least one person who holds a current U.S. commercial or airline transport pilot certificate and is properly rated for the aircraft — the applicant may be that person. The pilot certificate is the airman credential; the agricultural aircraft operator certificate is a separate operating authorization. See why we track pilot-logbook records and operator records as distinct objects.
§137.19(d) / §137.31 — The Aircraft and the Shoulder Harness
§137.19(d) requires the applicant to have at least one certificated and airworthy aircraft equipped for agricultural operation. That requirement is reinforced operationally by §137.31 (Aircraft requirements), which prohibits operating an aircraft in agricultural operations unless it meets §137.19(d) and is equipped with a suitable, properly installed shoulder harness for use by each pilot. The airworthiness evidence behind the aircraft — its ARROW documents and §43.9 maintenance-record entries — is the same airworthiness layer that governs any civil aircraft.
§137.19(e) — The Knowledge and Skill Demonstration
§137.19(e) requires the applicant — or the person designated as chief supervisor of agricultural aircraft operations for the applicant — to show satisfactory knowledge and skill as described in §137.19(e)(1) and (2). We break the items down in the next section. The key compliance point: the date the operator and each pilot met these requirements is itself a tracked data field under §137.71(a)(4).
The economic-poison knowledge carve-out (§137.19(a))
§137.19(a) provides that if an applicant applies for an agricultural aircraft operator certificate containing a prohibition against dispensing economic poisons, that applicant is not required to demonstrate the knowledge required in §137.19(e)(1)(ii) through (iv) — the safe-handling, poison-effects, and poisoning-symptom items. An operator who will only dispense non-poison substances (seed, fertilizer) can be certificated without those three knowledge items, but still must show the remaining §137.19(e)(1) knowledge and the §137.19(e)(2) flight-skill maneuvers. If a certificate carries that prohibition, dispensing an economic poison under it would be operating outside the certificate's terms.
Knowledge and Skill Tests — 14 CFR §137.19(e)
§137.19(e) is titled Knowledge and skill tests. It requires the applicant, or the designated chief supervisor of agricultural aircraft operations, to show satisfactory knowledge and skill. The two components — knowledge (e)(1) and skill (e)(2) — are listed item-by-item in the rule.
§137.19(e)(1) — Knowledge (six items)
- (i) Steps to be taken before starting operations, including survey of the area to be worked
- (ii) Safe handling of economic poisons and the proper disposal of used containers
- (iii) The general effects of economic poisons and their toxic agents on plants, animals, and persons, and the precautions to be observed
- (iv) The primary symptoms of poisoning of persons from economic poisons, the appropriate emergency measures, and the location of poison-control centers
- (v) The performance capabilities and operating limitations of the aircraft to be used
- (vi) Safe flight and application procedures
§137.19(e)(2) — Skill (demonstrated maneuvers)
- Short-field and soft-field takeoffs (airplanes and gyroplanes only)
- Approaches to the working area
- Flare-outs
- Swath runs
- Pullups and turnarounds
- Rapid deceleration (quick stops) (helicopters only)
The skill maneuvers are demonstrated in an aircraft of the category for which authorization is sought. The rule lists the maneuvers; it does not, by its text, name a single mandatory observer.
Personnel: §137.41 carries §137.19(e) into your crew
The knowledge-and-skill standard does not stop at certification. §137.41 (Personnel) requires that each person used in the operation be informed of that person's duties and responsibilities (§137.41(a)); that a supervisor of agricultural aircraft operations have met the §137.19(e) knowledge and skill requirements (§137.41(b)); and that each pilot in command hold the appropriate airman certificate and rating and have demonstrated to the certificate holder that the pilot meets the §137.19(e) knowledge and skill requirements (§137.41(c)). That demonstration date for each pilot is exactly what §137.71(a)(4) tells a commercial operator to record. The parallel here is the same skill-and-currency discipline behind Part 135 pilot records and Part 135 training-program records — different rule, same idea: prove each airman is qualified, and date it.
Carrying the Certificate — 14 CFR §137.33
§137.33 (Carrying the agricultural aircraft operator certificate) is short but operationally important — and it is the section most often confused with a generic "carry your documents" rule.
§137.33(a) — Facsimile in the aircraft
No person may operate an aircraft unless a facsimile of the agricultural aircraft operator certificate under which the operation is conducted is carried on that aircraft. The facsimile must be presented for inspection on the request of the Administrator or any Federal, State, or local law-enforcement officer. Note the breadth: this is one of the rules where state and local law enforcement — not only the FAA — can demand to see the document.
§137.33(b) — Registration & airworthiness at base
§137.33(b) relieves the operator from carrying the aircraft registration certificate and airworthiness certificate in the aircraft, provided they are kept available for inspection at the base from which the dispensing operation is conducted. This is a practical accommodation for low-altitude application aircraft that operate from a fixed base — but the documents must genuinely be available at that base, which is itself a records-management obligation.
The interaction is worth holding onto: the operator-certificate facsimile travels with the aircraft, while the registration and airworthiness certificates may stay at base if kept available there. For aircraft that keep ARROW documents aboard out of habit, §137.33(b) is a relaxation — but the airworthiness paperwork still has to exist and be findable. See the ARROW documents guide for what those certificates are and how they tie to the aircraft's current airworthiness status.
The Records a Commercial Operator Must Keep — 14 CFR §137.71
This is the heart of Part 137 recordkeeping. §137.71 is titled Records: Commercial agricultural aircraft operator. By its heading and text, it applies to holders of a commercial agricultural aircraft operator certificate. §137.71(a) requires the operator to maintain and keep current, at the home base of operations, four record categories.
| §137.71(a) item | What it requires |
|---|---|
| (1) | The name and address of each person for whom agricultural aircraft services were provided |
| (2) | The date of the service |
| (3) | The name and quantity of the material dispensed for each operation conducted |
| (4) | The name, address, and certificate number of each pilot used in agricultural aircraft operations, and the date that pilot met the knowledge and skill requirements of §137.19(e) |
Three observations operators consistently miss. First, item (4) is a pilot-qualification record, not just a dispensing log — it ties straight back to §137.19(e) and §137.41(c), and it requires the date each pilot met the knowledge and skill requirements. Second, item (3) is per-operation: the material name and quantity for each operation, not a monthly total. Third, the records live at the home base of operations — the same base referenced in §137.33(b) and the address governed by §137.75.
Two section numbers operators misremember
§137.71 is the records rule. It is not §137.75 — that section is Change of address, which requires the certificate holder to notify the FAA in writing of any change in the address of the home base of operations. And §137.77 is Termination of operations, which requires surrendering the certificate to the responsible Flight Standards office when operations cease. If you are looking for the recordkeeping obligation, it is §137.71 — cite the right section and you save yourself an argument with an inspector.
Note that Subpart D itself is narrow — it contains only §137.71 (Records), §137.75 (Change of address), and §137.77 (Termination of operations); there is no Part 137 incident-reporting section. Hazardous-materials and pesticide incident-reporting duties live outside Part 137 (for example the DOT hazmat incident rules at 49 CFR 171.15/171.16, plus EPA/state pesticide-program requirements). The dispensing records under §137.71 are the standing operational record; keeping them clean makes any such report — and any hazardous-materials documentation — far easier to assemble.
Retention and Inspection — §137.71(b)
§137.71(b) sets the retention floor: the records required by §137.71 must be kept at least 12 months and made available for inspection by the Administrator upon request. That is the entire federal Part 137 retention rule for these records — short, explicit, and easy to under-keep.
"At least 12 months" is a floor, not a ceiling
The §137.71(b) minimum is 12 months. In practice most aerial-application operators keep dispensing records considerably longer because state pesticide-application statutes, EPA recordkeeping rules for restricted-use pesticides, and product-liability exposure frequently demand multi-year retention. The federal aviation minimum and the retention period you should actually run are usually different numbers — and the longer one typically wins. FileFlo tracks the §137.71(b) 12-month floor as the regulatory baseline while letting you set a longer retention policy on top of it.
Compare this with the retention tiers elsewhere in the FARs and the contrast is sharp. A Part 91 operator's aircraft maintenance records and airworthiness-directive compliance records run on §91.417 tiers — some until the work is superseded, some for the life of the aircraft. A Part 135 certificate holder carries drug-and-alcohol program records on retention schedules set by 49 CFR Part 40. Part 137's flat 12-month floor is one of the shortest standing-record retention windows in the regulations — which is precisely why it is easy to let lapse before a surveillance visit or records request.
The §137.71(a)(4) pilot-date field is the one most likely to be missing
In real records reviews, the customer name, service date, and material/quantity fields are usually present — they map to the load tickets and work orders an operation already generates. The field that goes missing is §137.71(a)(4): the date each pilot met the §137.19(e) knowledge and skill requirements. It lives in personnel files, not load tickets, so it is the field most often absent when the Administrator asks. Treating it as a tracked compliance date — the way you would a medical-certificate expiration — is the single highest-value records habit a commercial Part 137 operator can build.
Staying Audit-Ready — Where a Compliance Document Layer Fits
Part 137 recordkeeping is small in volume but unforgiving in specifics: four record categories, a 12-month floor, and one pilot-qualification date that hides in personnel files. The risk is not that the records are voluminous — it is that they are scattered across load tickets, work orders, pilot files, and a base filing cabinet, and that no single place shows whether all four §137.71(a) categories are current and within the §137.71(b) window.
Keep your Part 137 records searchable, current, and audit-ready
FileFlo is a compliance document intelligence platform — a read-only proof layer. It does not dispense chemicals, file state pesticide reports, or run your operation. It organizes the documents that prove Part 137 compliance:
- Classifies each uploaded record against the governing reference — the §137.71(a) dispensing-log fields, the §137.19(e) pilot knowledge-and-skill demonstration date, the airworthy-aircraft and shoulder-harness evidence under §137.19(d)/§137.31, and the operator-certificate facsimile under §137.33
- Indexes records so all four §137.71(a) categories — customer, date, material/quantity, and pilot/knowledge-date — are retrievable in one place
- Tracks the §137.71(b) 12-month retention floor as the regulatory baseline, with room for a longer state/EPA retention policy on top
- Assembles an audit-ready binder if the Administrator requests records under §137.71(b) — organized by the §137.71(a) item
FileFlo sits alongside your operation and your Flight Standards relationship — it does not replace your chief supervisor, your A&P/IA, or your state pesticide-application authority. It keeps the documents that prove your compliance audit-ready. Starter $89/mo · Professional $299/mo · 5-day free trial, no credit card required.
If you also run charter or fly larger aircraft, the same proof layer covers the adjacent regimes — from operational control in Part 135 to the SMS 2027 deadline — without forcing your Part 137 dispensing records into a system built for a different certificate.
Frequently Asked Questions
What is an agricultural aircraft operator certificate, and who needs one?
Under 14 CFR Part 137, anyone conducting an agricultural aircraft operation in the United States must hold an agricultural aircraft operator certificate. 14 CFR §137.3 defines an agricultural aircraft operation as operating an aircraft to dispense any economic poison, to dispense any other substance intended for plant nourishment, soil treatment, propagation of plant life, or pest control, or to engage in dispensing activities directly affecting agriculture, horticulture, or forest preservation — but it does not include dispensing live insects. The rule provides two certificate types: a private agricultural aircraft operator certificate and a commercial agricultural aircraft operator certificate. Per §137.19(a), a private applicant must meet paragraphs (b), (d), and (e) of §137.19, and a commercial applicant must meet paragraphs (c), (d), and (e). The dividing line in practice is whether you dispense for others for compensation (commercial) or only on land you own, lease, or rent and operate (private).
What does 14 CFR §137.19 require to get certificated?
14 CFR §137.19 (Certification requirements) sets three substantive gates. Pilot qualification: §137.19(b) requires a private applicant to hold a current U.S. private, commercial, or airline transport pilot certificate, properly rated for the aircraft; §137.19(c) requires a commercial applicant to have available the services of at least one person holding a current U.S. commercial or airline transport pilot certificate, properly rated for the aircraft (the applicant may be that person). Aircraft: §137.19(d) requires at least one certificated and airworthy aircraft equipped for agricultural operation. Knowledge and skill: §137.19(e) is titled Knowledge and skill tests and requires the applicant — or the person designated as chief supervisor of agricultural aircraft operations — to show satisfactory knowledge and skill as described in §137.19(e)(1) and (2). The knowledge items in §137.19(e)(1) run (i) through (vi) and cover pre-operation steps and area survey, safe handling and disposal of economic poisons, the general effects of poisons and chemicals on plants/animals/persons and the precautions, poisoning symptoms and emergency measures, aircraft performance and operating limitations, and safe flight and application procedures. The skill items in §137.19(e)(2) are demonstrated maneuvers such as short-field and soft-field takeoffs (airplanes and gyroplanes), approaches to the working area, flare-outs, swath runs, pullups and turnarounds.
Does my pilot certificate alone qualify me to dispense agricultural chemicals by air?
No. A pilot certificate is necessary but not sufficient. 14 CFR §137.19(b) and (c) establish the pilot-certificate floor (private/commercial/ATP, properly rated), but the agricultural aircraft operator certificate itself is a separate operating authorization issued under Part 137. You also need an airworthy aircraft equipped for agricultural operation under §137.19(d), and you (or your designated chief supervisor) must demonstrate the §137.19(e) knowledge and skill. Separately, §137.31 (Aircraft requirements) prohibits operating in agricultural operations unless the aircraft meets §137.19(d) and is equipped with a suitable, properly installed shoulder harness for each pilot. The pilot logbook documents airman currency; the operator certificate, the aircraft equipment, and the §137.19(e) knowledge/skill demonstration are distinct compliance objects. See our guide on the difference between a pilot logbook and operator records for why these layers are tracked separately.
What records must a Part 137 operator actually keep?
The recordkeeping rule is 14 CFR §137.71 (Records: Commercial agricultural aircraft operator). It applies to holders of a commercial agricultural aircraft operator certificate. §137.71(a) requires the operator to maintain and keep current, at the home base of operations, four record categories: (1) the name and address of each person for whom agricultural aircraft services were provided; (2) the date of the service; (3) the name and quantity of the material dispensed for each operation conducted; and (4) the name, address, and certificate number of each pilot used in agricultural aircraft operations and the date that pilot met the knowledge and skill requirements of §137.19(e). §137.71(b) sets the retention rule: the records required by this section must be kept at least 12 months and made available for inspection by the Administrator upon request. Note the structure trap: §137.75 is Change of address, not a records section, and §137.77 is Termination of operations (surrender of the certificate) — neither is the recordkeeping rule.
How long must Part 137 agricultural dispensing records be retained?
At least 12 months. 14 CFR §137.71(b) states that the records required by §137.71 must be kept at least 12 months and made available for inspection by the Administrator upon request. That is a notably short retention window compared with the multi-year and life-of-aircraft retention tiers elsewhere in the FARs — for example, the §91.417 maintenance-record tiers or the indefinite pilot-records obligations a Part 135 certificate holder carries. "At least 12 months" is a floor, not a ceiling: applicators routinely keep dispensing records far longer because state pesticide-application law, EPA recordkeeping, and product-liability exposure often demand it. But the federal Part 137 minimum is 12 months, and it attaches to the four §137.71(a) categories.
Do I have to carry the agricultural aircraft operator certificate in the aircraft?
You must carry a facsimile of it. 14 CFR §137.33 (Carrying the agricultural aircraft operator certificate) prohibits operating an aircraft unless a facsimile of the agricultural aircraft operator certificate under which the operation is conducted is carried on that aircraft, and that facsimile must be presented for inspection on the request of the Administrator or any Federal, State, or local law enforcement officer. §137.33(b) provides that the aircraft registration certificate and airworthiness certificate need not be carried in the aircraft if they are kept available for inspection at the base from which the dispensing operation is conducted. So the operator-certificate facsimile travels with the aircraft; the registration and airworthiness certificates may stay at base if they are kept available there.
What is the difference between a private and a commercial agricultural aircraft operator certificate?
The two certificate types are built from different paragraphs of §137.19. Per §137.19(a), a private agricultural aircraft operator must comply with paragraphs (b), (d), and (e); a commercial agricultural aircraft operator must comply with paragraphs (c), (d), and (e). The recordkeeping rule, §137.71, is written for the commercial certificate holder — its heading is Records: Commercial agricultural aircraft operator. There is also a knowledge-test carve-out in §137.19(a): if an applicant applies for a certificate containing a prohibition against dispensing economic poisons, that applicant is not required to demonstrate the knowledge required in §137.19(e)(1)(ii) through (iv) — the poison-handling, poison-effects, and poisoning-symptom items. In other words, an operator who will only dispense non-poison substances (such as seed or fertilizer) can be certificated without the three economic-poison knowledge items, but still must show the remaining knowledge and the §137.19(e)(2) flight-skill maneuvers.
How does FileFlo help a Part 137 operator stay audit-ready?
FileFlo is a compliance document intelligence platform — a read-only proof layer. It does not dispense chemicals, file state pesticide reports, or run your operation. What it does is organize the documents that prove Part 137 compliance: it classifies each uploaded record against the governing reference (the §137.71(a) dispensing log fields, the §137.19(e) pilot knowledge-and-skill demonstration date, the airworthy-aircraft and shoulder-harness evidence under §137.19(d)/§137.31, and the operator-certificate facsimile under §137.33), indexes them so the four §137.71(a) categories are retrievable in one place, tracks the §137.71(b) 12-month retention floor, and assembles an audit-ready binder if the Administrator requests records under §137.71(b). The operator still owns the recordkeeping; FileFlo keeps the proof of it searchable, current, and ready to present.
Chad Griffith
Founder, FileFlo — compliance document intelligence
This article is a compliance document perspective, not legal, airworthiness, or aerial-application advice. It explains what 14 CFR Part 137 requires at the certificate and records layer; it is not a substitute for guidance from your Flight Standards office, an aviation attorney, an A&P/IA, or your state pesticide-application authority on any specific operation. Regulatory citations were checked against the current Code of Federal Regulations; always confirm the live text before acting.
Related Aviation Compliance Guides
What Records Must a Part 135 Operator Keep?
The full Part 135 operator record set — distinct from a Part 137 ag certificate
Part 135 Pilot Records Required by the FAA
The pilot-qualification records discipline that mirrors §137.71(a)(4)
ARROW Documents Explained
Airworthiness and registration certificates — and the §137.33(b) at-base accommodation
§43.9 Maintenance Record Entries
How maintenance entries document the airworthy aircraft §137.19(d) requires
Aviation Hazmat & Dangerous Goods Records
The hazardous-materials documentation that touches economic-poison dispensing
Pilot Logbook vs. Operator Records (§61.51)
Why airman records and operator records are tracked as separate objects
Keep your Part 137 records ready before the Administrator asks
FileFlo classifies your agricultural-operation records against 14 CFR §137.71 and §137.19(e), keeps all four §137.71(a) categories retrievable in one place, tracks the 12-month retention floor, and assembles an audit-ready binder on demand. Keep your dispensing logs, pilot-qualification dates, and operator-certificate facsimile documented and current.
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