Aug. 17, 2021
Association members trying to decipher and comply with the new Pilot Records Database (PRD) regulations may find assistance from NBAA’s new Pilot Records Database Resource Guide. The first compliance date for the FAA’s new PRD comes Sept. 8.
The FAA published the final rule establishing Part 111, Pilot Records Database, in May. 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
NBAA’s new guide helps operators determine if they’ll have obligations under the new rule and the deadline for meeting those obligations. For example, the guide explains all applicable operators must have a responsible person register by Sept. 8.
“If they haven’t already, operators should familiarize themselves with the PRD web-based application by setting up an account in MyAccess so that they are able to both upload pilot records, as well as view pilot records,” said Alison Squiccimarro, from the Law Offices of Paul A. Lange. “Additionally, operators should review the procedures because there are some new obligations for operators. Most notably is the requirement that operators have a process for addressing reports of inaccuracies from employees and former employees.”
Squiccimarro explained this process must allow pilots the opportunity to alert the operator of an inaccuracy in records uploaded to the PRD, provide operators 10 days to correct inaccurate records and include a dispute resolution process when a pilot and operator disagree about the accuracy of records reported by the operator to the PRD.
Marina O’Brien, of Holland & Knight, and Squiccimarro were the principal authors of the new guide.
International Business Aviation Council Ltd.