FAA Pilot Records Database enforcement campaign coming

The PRD was proposed in 2020 and became a rule in 2021 to replace the Pilot Records Improvement Act of 1996 (PRIA) with an electronic database to enable air carriers and other operators to see an applicant’s flight qualifications and past safety records provided by the FAA and the applicant’s previous employers.

Of the more than 600,000 certificated pilots in the United States, only a small group of pilots and operators were subject to PRIA. With the introduction of the PRD, air carriers and operators would be able to verify the information, certification, training, and currency of commercial, airline transport pilot, (and Part 107 certificated pilots they employ. In addition, the PRD will expand required reporting and accessing of information beyond that of existing PRIA requirements resulting in an increased number of pilots and operators required to comply, including several small, sole-practitioner operations, and pilots with no plans to work for an air carrier. AOPA pushed back against requiring these Part 91 operations to comply in its 2020 letter to the FAA arguing that it “casts a much wider non-mandated net of applicability than PRIA and will unnecessarily create additional requirements that will negatively impact thousands of small and sole-practitioner part 91 operators.” However, the FAA responded, saying certain Part 91 operations are “gateway operators” to larger Part 121 air carriers that should require reporting to and review of PRD records.

Although the PRD will not be fully implemented until September 2024, some deadlines and requirements are already in effect. This is a reason for the FAA’s recent announcement in its Notice 8900.655 Pilots Records Database Compliance Oversight. There, the FAA listed several compliance requirements and deadlines as well as potential findings of noncompliance by operators who did not apply for database access by the September 8, 2021, deadline; did not report new pilot records; and may have hired pilots without reviewing the FAA records in the PRD. The FAA added that according to their access records, some Part 121 operators have not accessed any pilot records since December 7, 2021.

If you are an operator who must comply with the requirements of the PRD (such as those conducting commercial air tours under FAR 91.147), don’t delay.

Affected pilots and operators can learn more about the PRD on the FAA’s Pilot Records Database FAQ document. To register and access the PRD visit the FAA website.