Steps for Complying with PRIA
The Pilot Records Improvement Act (PRIA) was enacted primarily as a result of certain airline accidents attributable to pilot error. The accident investigations found that although the pilot or pilots had a history of poor performance, their backgrounds were not investigated by the current employers. While many of the PRIA requirements apply only to commercial air carriers, there are implications for operators conducting flights under Part 91 of the Federal Aviation Regulations (FARs). Under PRIA, a commercial air carrier cannot allow a pilot to conduct flights until it obtains and reviews the last 5 years of the pilot’s background and safety records.
Due to several high profile accidents involving Part 121 air carriers, various amendments to PRIA were signed into law during 2010. Specifically, the FAA is now required to create a pilot records database (PRD) that will contain pilot records dating from Aug. 1, 2005, FAA certification events, enforcement records, air carrier employment history and training data, and National Driver Register data. Once implemented, the PRD, including information submitted by the employer, will largely replace the current PRIA process. However, the date for implementation is still unclear. In the interim, June 2016, the FAA issued an updated Advisory Circular on PRIA, AC-12068G.
Detailed information on operators’ responsibility to make or respond to PRIA requests can be found in the NBAA resource Pilot Records Improvement Act Guide.
PRIA Requirements for Part 91 Operators
Since Part 91 operators do not meet the definition of an air carrier, they are not required to request PRIA records when hiring a pilot. However, certain records must be retained by Part 91 operators in case they receive a records request from an air carrier.
Within 30 days after receiving a PRIA request, the Part 91 operator must provide records pertaining to:
- Training, qualification, proficiency, or professional competency of the pilot;
- any disciplinary action that was not subsequently overturned;
- any release from employment or resignation, termination, or disqualification with respect to employment; and
- any FAA-mandated alcohol and drug testing program results.
In many cases, a Part 91 operator may not have any records on the pilot that would be pertinent to the PRIA request. In these situations, a simple letter to the requestor stating that no records are available satisfies the regulatory requirements.
PRIA Requirements for Part 135 Operators
Operators that fly either full-time or part-time under FAR Part 135 are required to gather specific past records of a new pilot within 90 days of hiring the person. The new Part 135 employer must request and receive records from anyone who has employed the applicant as a pilot during the past five years. This request must include a signed written consent of the pilot applicant. The consent immunizes the former employer from any Federal, state, or local lawsuits brought by the pilot, unless the information provided is intentionally false.
Pilot Records Database (PRD)
The FAA published the final rule establishing Part 111, Pilot Records Database, in May 2021. The new rule introduces the electronic PRD with new mandates for certain aircraft operators with the intent to improve safety by improving the pilot hiring process. Operators required to submit and review information in the PRD include:
- Part 119 certificate holders
- Operators who perform operations under the fractional ownership rules
- Air tour operators holding a letter of authorization
Entities required to report information to the PRD include operators listed above, plus:
- Entities conducting public aircraft operations
- Corporate flight departments (as defined in the PRD rule) and specific entities operating under Part 125
- A trustee appointed by a bankruptcy court for an operator or entity subject to the reporting requirements.
To help NBAA members determine if they’ll have obligations under the new rule, NBAA has developed a resource
For additional information on the PRD see:
The FAA PRIA website provides a number of guidance documents:
- Advisory Circular 120-68G, June 21, 2016 (1 MB, PDF)
- Introduction to PRIA (MS Powerpoint) (2 MB, PPT)
- Information Provided by PRIA, FOIA, and the Privacy Act (100 KB, PDF)
- PRIA Request Process Flowchart (60 KB, RTF)
- PRIA Process Overview (64 KB, RTF)
For additional questions contact the NBAA Operations Service Group at 202-783-9250 or firstname.lastname@example.org.