Warning that the FAA is going to begin enforcing pilot records database (PRD) compliance deadlines, NBAA is urging operators to catch up on any requirements they may have missed. The FAA this month released Notice 8900.653 Pilot Records Database Compliance Oversight, providing PRD direction and enforcement criteria for aviation safety inspectors.
In a “potential findings” section of the notice, the FAA notes, “Many operators, particularly non-Part 121 operators, did not submit an application for database access by Sept. 8, 2021” and further added, “PRD access activity data shows that some of the Part 121 operators have not accessed any pilot records as of Dec. 7, 2021, when they were required to start using the PRD for such information.”
Additionally, the agency added that noncompliance with PRD historical recordkeeping requirements will make future reporting compliance “improbable.”
“If you inadvertently missed the deadline to apply for the database access or any of the additional deadlines, apply now and develop internal processes to come into compliance and remain in compliance,” said Brian Koester, NBAA director of flight operations and regulations. “While there might still be consequences for failing to meet previous deadlines, the notice instructs inspectors to follow the compliance program policy, which tends to look favorably upon operators that correct instances of noncompliance before FAA interaction and develop corrective actions to ensure future compliance.”
Released in May 2021, the PRD rule includes record-keeping requirements for a wide swath of the industry from corporate and fractional ownership operators to air tours, public charters, and on-demand and scheduled air carriers, among others. It further requires certain air carriers and operators to access the PRD before hiring pilots.
The rule included a series of compliance deadlines beginning in September 2021 with registration to the database and in December 2021 for certain carriers and operators to begin reviewing database information. Operators were required to submit new pilot records into the system beginning in June 2022. Historical information dating to 2015 must be submitted by June 12 and older records must be submitted by Sept. 9, 2024.
The FAA has instructed its inspectors to evaluate Part 135 compliance by the end of this month, Part 125 and 91(K) compliance by the end of June, and corporate operator compliance by the end of August.