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here we go again, thanks FAA

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LJ45

Well-known member
Joined
Jan 2, 2005
Posts
1,080
when will the NATA, NBAA, AOPA.. etc, have enough balls to stop this crap the FAA keeps coming up with?

NATA: Database Updates Are Maintenance Tasks
The National Air Transportation Association (NATA), responding to recent member requests, issued a statement that clarifies FAA regulations that apply to updates of navigational databases used on modern avionics. The FAA changed the Part 43 Appendix A regulations in 1996, according to NATA, and classified database updates as preventive maintenance instead of maintenance. This change allowed pilots operating under Part 91 regulations to perform database updates, but as NATA noted, “for aircraft maintained under Part 135, the tasks must be completed by a technician. Many operators find this surprising, as typically navigational updates are very simple to accomplish using a memory flash drive or similar device.” And even though installing a database update seems like a simple task, because it is classified as a maintenance task the person performing the update must make a proper entry in the maintenance records, NATA noted. Preventive maintenance items listed in Part 43 Appendix A count as maintenance whether a pilot operating under Part 91 or an FAA-certified technician is performing the task.
 
I guess I am the only single plane operator without a dedicated maintenance staff that this could affect.
 
Good, then the wrench turner can come over and update my paper database as well!

They want to play that game, I'll make the argument that if the electronic database falls in that category, so does the paper!

Bring it on!
 
when will the NATA, NBAA, AOPA.. etc, have enough balls to stop this crap the FAA keeps coming up with?

This has long been the case, is not new, and is hardly "crap."

Operators under Part 121 and 135 are held to higher standards in many areas, in the public interest, as operators holding out for common carriage.

I've seen pilots update a database and go fly, only to find out that the database they entered in the FMS or EFB did indeed load correct...but was for the wrong geographic location. On one occasion, I noted that the pilot had correctly entered the update...but failed to note that instead of the United States, it was an African database. Part of the the update processs involved deleting the former database, as is usually the case, leaving nothing usable.

Requiring a certified technician to perform maintenance tasks has always been standard under part 135, with some very narrow exceptions (such as removing seats or installing a stretcher/gurney, provided it doesn't require complex disassembly or tools). More on point, maintenance, including preventative maintenance, has always required log entries. This continues to be the case. As you may or may not be aware, failure to complete the log entries, including the update of an airborne data base, invalidates the aircraft airworthiness certificate.

They want to play that game, I'll make the argument that if the electronic database falls in that category, so does the paper!

No game. Paper vs. plastic is a rather stupid argument.

Updating equipment attached to the airworthiness of the airplane is a maintenance function, be it strictly preventative, or be it a change in the legal capability of the system. These affect airworthiness, and as such are the direct concern of those charged with the maintenance of the aircraft. This may be the director of maintenance who holds responsibility for the condition, record keeping, upkeep, function, and update of the airframe, avionics, powerplants, and appliances, it may also include the mechanic in the field or on the shop floor who does the work.

Updating paper charts in no way affects the airworthiness of the airframe or systems thereof. It's an operational issue, and falls under the flight department. Such a task is tailor made for pilots. Not mechanics.
 
Well Avbug, I guess we'll just agree to disagree, as I don't see inserting a single disk, pressing load, then selecting Check All, as being a maintenance function.

But I'll play. The feds can make all the rules they want, but the more they do, the more I'm going to walk into my local FSDO and DEMAND they accept an alternate means of compliance for times when the aircraft is operated in areas where no "suitable maintance" exists. The FAA dislikes it very much, and become MUCH easier to deal with on these types of matter, when you start talking about a "restraint of trade complaint".
 
This has long been the case, is not new, and is hardly "crap."

Requiring a certified technician to perform maintenance tasks has always been standard under part 135, with some very narrow exceptions (such as removing seats or installing a stretcher/gurney, provided it doesn't require complex disassembly or tools). More on point, maintenance, including preventative maintenance, has always required log entries. This continues to be the case. As you may or may not be aware, failure to complete the log entries, including the update of an airborne data base, invalidates the aircraft airworthiness certificate.

.

we have the one disk for the whole world, so that does fly in my situation.
So lets see, I come back from a trip late on a Friday night and I am going back out Sunday, I have to call out a contract "technician" to load up a freaking single zip disk. I have only been doing this for 13 years without a problem and with the blessing of my POI who told me to make an entry into our flight log for the update, so lets see if they say something now.
 
we have the one disk for the whole world, so that does fly in my situation.

Irrelevant.

I have only been doing this for 13 years without a problem

Irrelevant.

Well Avbug, I guess we'll just agree to disagree, as I don't see inserting a single disk, pressing load, then selecting Check All, as being a maintenance function.

How you see it is irrelevant.

The feds can make all the rules they want, but the more they do, the more I'm going to walk into my local FSDO and DEMAND they accept an alternate means of compliance for times when the aircraft is operated in areas where no "suitable maintance" exists. The FAA dislikes it very much, and become MUCH easier to deal with on these types of matter, when you start talking about a "restraint of trade complaint".

Local FSDO? Irrelevant.

The FSDO level does not now, and never has made, nor interpreted regulation. Moreover, whatever is obtained at the FSDO level, even in writing, is not binding, and is no legal defense. The FSDO level does not have the authority.

However, you're welcome to address the FAA Chief Legal Counsel on the matter.

Proper maintenance is not restraint of trade. Regulations regarding the update and record keeping of permanently installed equipment databases is not new, and neither is the interpretation thereof.
 
Deviation needed, are you happy now? are we safer now?
 
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I've seen pilots update a database and go fly, only to find out that the database they entered in the FMS or EFB did indeed load correct...but was for the wrong geographic location. On one occasion, I noted that the pilot had correctly entered the update...but failed to note that instead of the United States, it was an African database. Part of the the update processs involved deleting the former database, as is usually the case, leaving nothing usable.

.

irrelevant, "technicians" screw up also. :smash:
 

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