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Medical certificate needed for 135 instruction?

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Prof. ATP

Well-known member
Nov 30, 2001
I'm hoping that someone on the forum has already fought this battle.

Can someone without a medical certificate but otherwise qualified as PIC act as a flight instructor under part 135? [It is clear that one can instruct under Part 61, as long as one does not act as a required crewmember. But Part 135 is different.]

Our POI says "no", using a convoluted reading of 135.338(e), which says "(e) An airman who does not hold a medical certificate may function as a flight instructor in an aircraft if functioning as a non-required crewmember, but may not serve as a flightcrew member in operations under this part." The convoluted reading is that the instructor is required to give instruction, so the instructor is a required crewmember. I would like to interpret required as "required by the type certificate", but he says his boss says no.

Since he doesn't have a medical, either, he would like to hear a different answer than the one he got.

Can anyone help?

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