International ops · October 31, 2026 · 6 min read · By BizJetDocs

What goes in an International Operations Manual (IOPM) for a Part 91 flight department

Why Part 91 operators need written oceanic procedures, what the FAA expects for B036, B039, B046 and A056, and a section-by-section IOPM outline.

Short answer: no Part 91 rule uses the words "International Operations Manual." What the FAA does require, LOA by LOA, is written operating procedures and training for oceanic, NAT HLA, RVSM and data link flying. Most flight departments put those procedures in one controlled manual, often called an IOPM or IOM, and that manual is what the inspector reviews when you apply for B036, B039, B046 and A056. AC 91-70D Change 1, Appendix G, gives the FAA's own list of "Suggested Subjects for Inclusion in Oceanic and International Procedures and/or an Operations Manual," and it is the best starting outline.

Why a Part 91 operator needs written procedures

The LOA guidance asks for procedures, not just equipment:

• B036. FAA Order 8900.1, Volume 3, Chapter 18, Section 4, says operators requesting B036 "must demonstrate that they have provided their flightcrews with operating procedures covering the breadth of typical oceanic/remote continental/RNP normal and contingency procedures, as well as training on those procedures." It names AC 91-70 as "the primary source of guidance on oceanic and remote continental operating procedures" and points inspectors to AC 91-70 Chapter 7 (in-flight contingencies), Appendix D (sample oceanic checklist) and Appendix G (suggested manual subjects).
• B039. The B039 guidance in the same section says the operator's training and flightcrew procedures "must address responses to a partial or complete loss of long-range navigation capability."
• A056. The A056 guidance in 8900.1, Volume 3, Chapter 18, Section 3, asks for documentation of the operator's data link policies and procedures, voice communication and SELCAL procedures, and normal and emergency data link procedures that comply with the current AC 90-117.
• B046. AC 91-85B, paragraph 5.5.2, says the FAA must find that the operator has adopted RVSM operating policies or procedures for pilots and that each pilot has adequate knowledge of them.

Outside the United States, 14 CFR 91.703(a) adds the rules of the air over the high seas (ICAO Annex 2) and the rules of each foreign country you fly in. A manual is where you show how your crews comply.

The streamlined route uses a PSOC

If you apply through the Streamlined Part 91 Operational Approval Application, the inspector checks your manual for a Procedures Statement of Compliance (PSOC). 8900.1, Volume 3, Chapter 18, Section 15, describes the PSOC as "a document prepared by a procedures provider, generally incorporated into a manual," that "lists the LOA procedural requirements met by the content of the manual." A PSOC must be signed by AFS-400 and the procedures provider and expires 24 months after the provider's signature unless it says otherwise. An expired or unsigned PSOC means the application is not processed through the streamlined route. More in the FAA streamlined LOA application.

A practical IOPM outline

The outline below follows AC 91-70D Change 1, Appendix G. Note 1 to that appendix says the list "is for reference only" and "not intended to be all-inclusive," and that the complexity of your operation and approvals decides which items apply.

1. Administration. Revision record, list of effective pages, distribution, who owns the manual and how crews are told about changes.
2. Regulations and references (G.1). 14 CFR, the ICAO documents (Doc 4444, Doc 7030, Doc 9574, Doc 9613, Doc 9869, the GOLD manual Doc 10037, Annex 2, Annex 6 and NAT Doc 007), the U.S. AIP, the related ACs (90-105, 90-117, 91-70, 91-85), NOTAMs and SFARs.
3. Navigation (G.2). Continental versus oceanic and remote navigation, and dead reckoning. The B036 guidance specifically says procedures and training "should account for the possible jamming or spoofing" of GPS, and that dead reckoning procedures are necessary for aircraft without an inertial system.
4. Flight planning (G.3). North American Routes, track messages, ATC flight plan codes, the operational flight plan cross-checks, equal time points, fuel (in particular ICAO Annex 6), special area requirements, plotting charts and the master document, weather charts, driftdown and WGS 84.
5. State operating restrictions (G.4).
6. RVSM (G.5). General description, metric flight levels where used, minimum equipment, contingencies, and temperature and tropopause considerations. AC 91-85B, paragraph 3.2, lists fifteen pilot knowledge subjects your RVSM section should cover, from flight level allocation schemes through severe turbulence and mountain wave activity.
7. Accidents, incidents and contingencies (G.6.1 and G.6.2). 49 CFR Part 175 and Part 830, weather deviations, lost communications, degraded navigation, depressurization, intercept and hijack.
8. Use of the navigation system (G.6.3). AFM supplement capabilities and limits, GPS integrity, inertial time limits, database currency, waypoint entry and expansion, independent verification.
9. Oceanic crossing (G.6.4). Oceanic checklist, master time source, position reports, waypoint checks and the five-minute post-position check.
10. Altimetry, transponder and CNS (G.6.5 to G.6.7). QNH, QNE, QFE, transition altitude and level, regional transponder requirements, RNP 10/4/2 airspace, ADS-C and CPDLC, HF, VHF and SATVOICE.
11. SLOP, volcanic ash and space weather (G.6.8 to G.6.10).
12. Operational control and oceanic speed control (G.6.11 and G.6.12).
13. Oceanic errors (G.6.13). Revised and conditional clearances and CPDLC route clearances. AC 91-70D Change 1 notes that in NAT HLA, without CPDLC or ADS-C in use, crews must report to ATC both when leaving and when reaching a new flight level.
14. Training. Who is trained, on what, how often, and the records you keep. Tie each LOA to the courses that cover it.
15. Data link procedures. Logon, failure, voice backup, and problem reporting, matching what A056 asks for.

Note 2 to Appendix G recommends a process to stay current in oceanic and international operations and describes that ongoing analysis as part of an operator's safety management system.

Checklist for a manual that will pass review

• Every procedure names who does it (pilot flying, pilot monitoring, or the operator) and when.
• The aircraft-specific parts match your AFM supplements and your MEL.
• Each LOA you request is cross-referenced to the manual paragraphs that satisfy it.
• References are to current editions (AC 91-70D Change 1 is dated October 19, 2026).
• The manual has revision control and a list of effective pages.
• Single-pilot certified aircraft have procedures built for one pilot. The B036 guidance notes that AC 91-70 procedures "assume at least two pilots are on duty."

What you submit and who submits it

The IOPM is an operator document. You do not send it to the FAA for approval by itself; it goes in your LOA application as the procedures evidence for B036, B039, B046 and A056, or carries the PSOC in a streamlined application. The operator, or a third party acting for an operator that keeps operational control, submits the application to the responsible Flight Standards office.

We write the IOPM for your aircraft, crew complement and routes, with a compliance cross-reference to each LOA you are requesting, and we give you the submission instructions. You review, sign and submit. Only the FAA decides on the LOAs.

Frequently asked questions

Is an IOPM required for Part 91?

Not by that name. The LOAs require documented procedures and training, and a single manual is the usual way to provide them.

Can I use the manufacturer's or a training provider's procedures?

You can build on them, but the manual must describe how your operation works. For the streamlined process, the procedures need a current, signed PSOC.

How often should the manual be revised?

Whenever a referenced document or your operation changes. AC 91-70 itself was revised in April 2025 and changed in October 2026.

Have it prepared

The International Operations Manual is $1,475, and the ICAO documentation binder for ramp inspections is $825. The International Operations Package adds A056, B036 and B046 for $3,650. See the format below.

Sources

Primary sources, as retrieved when this article was last updated. Check the current text before you rely on it.

• AC 91-70D Change 1, Oceanic and Remote Continental Airspace Operations (10/19/2026)
• FAA Order 8900.1, Volume 3, Chapter 18, Section 4, Part B Operations Specifications (CHG 1067)
• FAA Order 8900.1, Volume 3, Chapter 18, Section 3, Part A Operations Specifications (CHG 1068)
• FAA Order 8900.1, Volume 3, Chapter 18, Section 15, Streamlined Part 91 Operational Approvals (CHG 973)
• AC 91-85B (editorial update), Authorization of Aircraft and Operators for Flight in RVSM Airspace
• 14 CFR 91.703, Operations of civil aircraft of U.S. registry outside of the United States

Informational only. Not legal advice, not FAA guidance and not a promise of FAA approval or of any FAA timeline. The operator submits its own application; only the FAA approves, accepts or issues an authorization.