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Pilot Records Database Compliance Deadline for Certain Part 91 Operators is June 10. Is Your Company Ready?

The Federal Aviation Administration (FAA) issued the final rule for the establishment of a new electronic pilot records database (PRD) on May 25, 2021, with the goal of providing transparency on pilot training deficiencies, discipline, and enforcement actions to keep unqualified pilots out of the cockpit. It replaced the prior Pilot Records Improvement Act, commonly known as PRIA.

PRIA applied to air carriers, but the new PRD rule expands the reporting requirements to Part 91 operators with at least two airplanes that require a type rating or at least two turbine powered helicopters (i.e., Covered Part 91 Operators).

Covered operators, including Covered Part 91 Operators, were supposed to register for PRD access by September 8, 2021. If you or your company have not done so, this is the first step in complying with the PRD regulations.

The next deadline for the Covered Part 91 Operators (and all other covered operators) is June 10, 2022, and it's a significant one. Starting on June 10, Covered Part 91 Operators must begin:

  • Retaining certain records for five years;
  • Uploading certain records to the PRD within 14 days of receipt of a request; and
  • Reporting a smaller subset of records automatically (i.e., without a request from a potential air carrier employer) within 30 days of their creation.

Retaining Records for Five Years

The records that Covered Part 91 Operators must retain for five years include records relating to currency, adverse training events (including comments from the check pilot or examiner), and disciplinary records, including termination of employment that could implicate an individual's performance as a pilot. There is no obligation to create records that the Covered Part 91 Operator did not previously create in the normal course of its operations, only to retain these records for five years.

Records Reportable Upon Request

In the event the Covered Part 91 Operator receives a request from another employer as part of a background check for a former employee, the Covered Part 91 Operator must upload the individual's records to the PRD within 14 days of the request.

Records That Must be Automatically Uploaded

There is an important additional requirement for records that relate to termination of a pilot due to professional disqualification or pilot performance or disciplinary records that relate to permanent or temporary suspension from piloting duties. These records must be uploaded to the PRD within 30 days without the need for a request from another employer.

This alert provides a brief overview of the new requirements. Please note there are additional, finer points regarding the types of records to retain and report and the procedures for accessing and using the PRD. If the new PRD regulations could apply to you or your company, please contact Jim Janaitis, Trey Range, or one of Baker Donelson's aviation attorneys to discuss how to prepare for the upcoming deadline.

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