No Need For Database Recordkeeping, AEA Clarifies

 - April 4, 2013, 1:05 PM

At the Aircraft Electronics Association convention held last week in Las Vegas, Ric Peri, AEA vice president of government and industry affairs, clarified new FAA rules governing avionics database updates during a regulatory training session. The new rules allow pilots to update databases, provided no tools are needed. Because the previous requirement was part of preventive maintenance but was removed from 14 CFR Part 43, “no records are required,” Peri said. “It is not a maintenance action.” Pilots do need to comply with avionics manufacturer or certificate holder instructions.


Hopefully AEA can straighten out the FAA on this because that is not their position.

As Ric Peri points out, this is the FAA's own regulations. If something is not listed as maintenance in the regulations, then there is no requirement to make a record of that. However, he also pointed out that this does not include software updates, which still require a record to be made because software updates are a maintenance action.

In the pt 135 world if the PIC does not do the update before the current database expires then it is deferred per MEL. That requires a signoff by an A+P to clear the MEL. So much for no record keeping. If this is truly not a maintenance item then database updates should not be on the MEL at all. AEA needs to look into this if their stand is that database updates are not maintenance. I already know this is not an issue for pt 91 operators.

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