Oct. 19, 2022

Three months have passed since the FAA’s updated Pilot Records Database (PRD) took full effect, and a session at the 2022 NBAA Business Aviation Convention & Exhibition (NBAA-BACE) addressed questions that pilots continue to have about its requirements and offered guidance for compliance.

The PRD moved the formerly paper-based recordkeeping required under the 1996 Pilot Records Improvement Act, or PRIA, to an online repository. It also expanded reporting requirements to many business aircraft operators flying under Part 91, in addition to air carriers – including those under Part 135 – and pilots.

“The heart of PRIA was to provide hiring employers with information about pilots, whether they were good pilots or had histories of problems or failed checkrides,” said Greg Reigel, an aviation attorney with Shackelford, Bowen, McKinley & Norton, LLP. “That wouldn’t necessarily mean the employer wouldn’t hire [pilots with reported issues], but they needed that information to make a proper evaluation.”

Operators required to submit and review pilot data to the PRD include Part 119 certificate holders, fractional ownership operators and air tour operators holding a letter of authorization. These, along with business aircraft operators with two or more turbine-powered aircraft, were required to submit pilot data to the PRD on June 10.

“While I haven’t seen the FAA chasing operators [who haven’t submitted data] that’s still a regulatory violation,” Reigel said. “You could be subject to enforcement and a likely civil penalty.”

Reigel noted NBAA and its members submitted comments to the FAA when the original PRD notice of proposed rulemaking was issued. While the FAA “wasn’t swayed” by arguments the PRD requirements posed an unfair burden on business aircraft operators, the agency has worked with operators to make the process as seamless as possible.

Still, “there is some administrative burden from this,” he continued. “To the extent that [pilot records are] produced or uploaded, you’ve got to have a separate record of that, and you don’t want everything together in one file. If you’re going to access [pilot records] and review, it has to be kept separate and can be only used for the purposes of evaluating a new hire.”

As for pilots, they are notified when their information has been requested by an employer or when changes have been made to their PRD records, usually related to discipline or termination. “The pilot may dispute those records,” Reigel noted, “requiring the reporting entity to either correct the record within 10 days, or launch an investigation and provide the results within 30 days.

“Intentionally entering false information to the PRD website violated criminal statutes,” he emphasized. “PRIA is treated like any other federal document, and false information will be treated as a federal violation, just as making a false statement on any other federal document.”

Review NBAA’s Pilot Records Database Resource Guide.

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