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FAA Issues Final Rule on Pilot Records Database

Pilots who fly for Commercial Air Carriers will be familiar with the Pilot Records Improvement Act (PRIA) and its procedures for the retention and forwarding of records to new employers, but some professional pilots may only recently be learning about the FAA’s new Pilot Records Database (PRD). 

The PRD will eventually replace PRIA, and per the PRD Final Rule,[1] it is being phased in over the next three years. In addition to Air Carriers, it imposes records retention and reporting requirements on smaller operators including some Corporate Flight Departments,[2] and on operators holding a Letter of Authorization (LOA) for 14 CFR § 91.147 Commercial Air Tours.[3]

 

The PRD will track many record types including among other things, FAA pilot certification information, verification of motor vehicle driving record, and employer records on training, qualification, and proficiency. However, the requirement to upload some types of records to the PRD varies by operator type, with Air Carriers facing the largest ongoing burden. Along with Public Aircraft operators, smaller operators like Corporate Flight Departments and Air Tour Operators will not be required to upload most types of records unless and until requested by a hiring operator.

 

Three exceptions which must be uploaded expediently even without a hiring operator request are Air Tour Operators’ drug and alcohol records subject to 14 CFR Part 120, separation from employment records when a pilot is terminated for pilot performance or professional disqualification, and disciplinary records when a pilot is suspended from flying.[4] Pilots can and should access their own PRD records free of charge to see if any errors are present, and dispute any inaccurate information as necessary.[5]

 



[1]https://www.faa.gov/news/media/attachments/Pilot_Records_Database_Final_Rule.pdf

[2]Specifically, those operating two or more aircraft that are any combination of: standard airworthiness and require a type rating, or turbine-powered; see 14 CFR § 111.1(b)(4).

[3]14 CFR § 111.1(b)(3).

[4]14 CFR § 111.215(b); 14 CFR § 111.220.

[5]14 CFR § 111.320; 14 CFR § 111.250.

Chad Mayer

Legal Services Plan, Attorney
Chad Mayer is an in-house attorney with AOPA’s Legal Services Plan who counsels Plan members on a daily basis. He is also a Commercial Pilot, a Remote Pilot with sUAS Rating, and an Advanced/Instrument Ground Instructor. The AOPA Legal Services plan is offered as part of AOPA’s Pilot Protection Services.

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