Loss-control documentation for charter operators: what to keep and how to present it

"Loss control" is the underwriting term for the things an operator does to reduce the frequency and severity of losses. Insurance brokers use it as a qualifier: operators with documented loss-control practices get placed more easily, with a broader set of markets, and often at better terms than those without.

For a Part 135 charter operator, loss control is not a compliance program separate from daily operations. It is the operational record of daily operations — the pre-dispatch checks, the FRAT assessments, the hazard reports, the corrective-action closures. The documentation already exists if the operation is being run properly. The question is whether it is organized in a form an underwriter can use.

The minimum: what every operator should have

These are table stakes. Any carrier that cannot produce them is starting the renewal conversation in a hole.

• Pilot records. Certificate, ratings, medical, training records (initial, recurrent, checkrides), 90-day currency log. Accessible in one place, not scattered across paper binders.
• Aircraft records. Airworthiness certificates, current W&B, MEL with open items tracked, maintenance logs, squawk resolution history.
• Certificate documentation. Part 135 certificate, OpSpecs, GOM, FSDO contact. Any recent surveillance activity or corrective-action letters.

The differentiator: what separates good renewals from great ones

The operators who get the best terms bring documentation that most carriers do not produce systematically.

Pre-dispatch compliance log

A tamper-evident record of every proposed assignment that went through a duty/rest, currency, and airworthiness check before dispatch. For each decision: what was checked, what the result was (CLEAR or UNABLE), and if UNABLE — what happened next. An override with no documentation is a liability. An override with a documented operational-control decision by the certificate holder under 14 CFR 135.77 is evidence of a functioning safety system.

The key word is tamper-evident. A spreadsheet someone updated retrospectively is not the same as a hash-chained append-only log. Underwriters are sophisticated enough to ask the question.

FRAT record

A flight-risk assessment tool score distribution over the trailing 12 months. GREEN / AMBER / RED counts, with the RED-band trips showing documented DO sign-off before dispatch. An operator with zero RED-band trips is either flying very conservatively or not running a FRAT. An operator with RED-band trips and documented sign-offs is demonstrating that the system is being used honestly.

Corrective-action register

Every hazard report, near-miss, or incident that triggered a corrective action — with the closure date and the action taken. A 90%+ closure rate on non-critical items is a positive signal. Open high-severity items with no closure date are a red flag. The existence of the register, and its completeness, matters more than a clean record.

DO methodology sign-off

If the compliance checks are running against a defined ruleset — not just "the pilot decides" — having a Director of Operations review and sign off on that methodology turns the system from an internal tool into an externally-reviewed process. Every audit report can then say "methodology reviewed by [DO, credential, date]" rather than "advisory."

How to present it

The artifact is a one- to two-page loss-control summary — a PDF the broker forwards to the underwriter as part of the submission package. It should include:

• Trailing-12-months compliance decision count, UNABLE catches, override count, illegal dispatches prevented.
• FRAT distribution.
• Corrective-action count and closure rate.
• Crew currency completeness.
• SMS readiness posture (Part 5 pillars: policy, risk management, assurance, promotion).
• An attestation line for the accountable manager to sign and date.

Do not promise premium outcomes in the cover letter. The broker draws that conclusion from the data. Your framing is "this is how we run the operation; here is the documentation."

How long to keep records

14 CFR 135.63 requires flight and duty records for 12 calendar months. Best practice for renewal purposes is to keep the trailing 24 months accessible — enough to show trend, not just snapshot. The last 12 for the current renewal; the prior 12 to anchor the comparison.