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Updating avionics databases no longer requires a logbook entry

Amendment(s) published November 29, 2012, in 77 FR 71096 § 43.3 Persons authorized to perform maintenance, preventive maintenance, rebuilding, and alterations. (k) Updates of databases in installed avionics meeting the conditions of this paragraph are not considered maintenance and may be performed by pilots provided... ( Más...

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Sam Tilley 1
I'm confused, is this just for 121 or for all aircraft?
Andrew Stagg 2
This change is for all operators (Part 91, Part 135 and Part 121). Previous FAR 43.3 had this statement:
(4) Records of when such database uploads have occurred, the revision number of the software, and who performed the upload must be maintained.
Are we sure that this actually applies to part 91?

(3) The holder of operating certificates must make available written procedures consistent with manufacturer's instructions to the pilot that describe how to:

(i) Perform the database update; and

(ii) Determine the status of the data upload.

If you're part 91, there is no "holder of operating certificates" for the operation, and thus. Can that part of the requirement be met under part 91?

I think the major applicability of this is that pilots can update GPSs under part 135 and 121, instead of MX.
Never mind, I'm incorrect about this. It looks like the removed the "Updating databases" from the list of preventative maintenance in Appendix A as well, so now it's not considered preventative maintenance at all.
Andrew Stagg 1
It looks like you got it figured out, but just to clarify, FAR 43 applies to all operators (Part 91, Part 135 and Part 121). In fact, FAR 43.3 (g) is where it specifies that pilots operating an aircraft under Part 91 may perform preventative maintenance.

The line you were referring to in 43.3 (k) actually says "(2) The pilot must comply with the certificate holder's procedures or the manufacturer's instructions." So Part 91 operators would just use the manufacturer (most commonly Garmin or Avidyne)'s instructions for doing the update.
I was actually more referring to the "operating certificate holder must supply" part. There is no operating certificate under part 91.

However reading the actual NFRM, it seems that the intent is that a part 91 operator would be his/her own operating certificate holder. Wish they made that explicit in the rule though.
Andrew Stagg 1
Yah I agree that's really poorly phrased, but (3) just says that the holder of an operating certificate must make instructions available and describes what information is needed in those instructions. The entirety of item (3) would not apply to Part 91 operators.
That's exactly my concern! 3 doesn't apply, but it is listed as a requirement that must be met.
Andrew Stagg 1
For (3) as a Part 91 operator, you don't have an operating certificate, so you do nothing and are still in compliance with 43.3(k).
Iskra 0
Really! They don't even make logbook entries at the airlines for this....


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