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Database Updates by Pilots

Other Procedures

Can pilots accomplish an aircraft database update without a mechanic? It depends. Are you just feeding a cockpit disk reader or connecting a USB stick to a cockpit port? Then the answer is probably yes. Are you hooking up a lap top computer to the airplane? Then the answer is probably no.


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Photo: The "special equipment" needed for a G450 database update

This isn't just a Gulfstream system, many Primus Epic aircraft are in the same boat. The database update process requires a laptop computer, cables, and a Local Area Network Tap. I've heard the Gulfstream G450 should have installations available sometime in 2019. (But I hear a lot of things that don't seem to happen when promised.)

14 CFR 43.3

The regulation looks pretty clear about this. When I read subparagraph (k) I was convinced that those of us who need to hook up a laptop computer were using "special equipment" but not everyone was convinced. But take a look for yourself, and then scroll down to the FAA's interpretation.

[14 CFR 43, ¶43.3]

(a) Except as provided in this section and §43.17, no person may maintain, rebuild, alter, or perform preventive maintenance on an aircraft, airframe, aircraft engine, propeller, appliance, or component part to which this part applies. Those items, the performance of which is a major alteration, a major repair, or preventive maintenance, are listed in appendix A.

(b) The holder of a mechanic certificate may perform maintenance, preventive maintenance, and alterations as provided in Part 65 of this chapter.

(c) The holder of a repairman certificate may perform maintenance, preventive maintenance, and alterations as provided in part 65 of this chapter.

(d) A person working under the supervision of a holder of a mechanic or repairman certificate may perform the maintenance, preventive maintenance, and alterations that his supervisor is authorized to perform, if the supervisor personally observes the work being done to the extent necessary to ensure that it is being done properly and if the supervisor is readily available, in person, for consultation. However, this paragraph does not authorize the performance of any inspection required by Part 91 or Part 125 of this chapter or any inspection performed after a major repair or alteration.

(e) The holder of a repair station certificate may perform maintenance, preventive maintenance, and alterations as provided in Part 145 of this chapter.

(f) The holder of an air carrier operating certificate or an operating certificate issued under Part 121 or 135, may perform maintenance, preventive maintenance, and alterations as provided in Part 121 or 135.

(g) Except for holders of a sport pilot certificate, the holder of a pilot certificate issued under part 61 may perform preventive maintenance on any aircraft owned or operated by that pilot which is not used under part 121, 129, or 135 of this chapter. The holder of a sport pilot certificate may perform preventive maintenance on an aircraft owned or operated by that pilot and issued a special airworthiness certificate in the light-sport category.

(h) Notwithstanding the provisions of paragraph (g) of this section, the Administrator may approve a certificate holder under Part 135 of this chapter, operating rotorcraft in a remote area, to allow a pilot to perform specific preventive maintenance items provided—

(1) The items of preventive maintenance are a result of a known or suspected mechanical difficulty or malfunction that occurred en route to or in a remote area;

(2) The pilot has satisfactorily completed an approved training program and is authorized in writing by the certificate holder for each item of preventive maintenance that the pilot is authorized to perform;

(3) There is no certificated mechanic available to perform preventive maintenance;

(4) The certificate holder has procedures to evaluate the accomplishment of a preventive maintenance item that requires a decision concerning the airworthiness of the rotorcraft; and

(5) The items of preventive maintenance authorized by this section are those listed in paragraph (c) of appendix A of this part.

(i) Notwithstanding the provisions of paragraph (g) of this section, in accordance with an approval issued to the holder of a certificate issued under part 135 of this chapter, a pilot of an aircraft type-certificated for 9 or fewer passenger seats, excluding any pilot seat, may perform the removal and reinstallation of approved aircraft cabin seats, approved cabin-mounted stretchers, and when no tools are required, approved cabin-mounted medical oxygen bottles, provided—

(1) The pilot has satisfactorily completed an approved training program and is authorized in writing by the certificate holder to perform each task; and

(2) The certificate holder has written procedures available to the pilot to evaluate the accomplishment of the task.

(j) A manufacturer may—

(1) Rebuild or alter any aircraft, aircraft engine, propeller, or appliance manufactured by him under a type or production certificate;

(2) Rebuild or alter any appliance or part of aircraft, aircraft engines, propellers, or appliances manufactured by him under a Technical Standard Order Authorization, an FAA-Parts Manufacturer Approval, or Product and Process Specification issued by the Administrator; and

(3) Perform any inspection required by part 91 or part 125 of this chapter on aircraft it manufactured under a type certificate, or currently manufactures under a production certificate.

(k) Updates of databases in installed avionics meeting the conditions of this paragraph are not considered maintenance and may be performed by pilots provided:

(1) The database upload is:

(i) Initiated from the flight deck;

(ii) Performed without disassembling the avionics unit; and

(iii) Performed without the use of tools and/or special equipment.

(2) The pilot must comply with the certificate holder's procedures or the manufacturer's instructions.

(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.

Gulfstream's Problem

Gulfstream's position has been that the laptop computer, coax cable, and everything in between is not "tools and/or special equipment" as described by 14 CFR 43.3. The first problem with the argument that this can be a pilot procedure is that it doesn't appear in any pilot manuals. The second is that where it appears in the maintenance manual calls the items used "special tools and test equipment."

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Photo: "Special Equipment," from G450 Maintenance Manual, §20-22-00, p. 245

Click photo for a larger image

The FAA's Interpretation

Gulfstream asked the question on our behalf and got the following answer from AFS-360.

It seems pretty cut and dried to me, though it wasn't the answer I wanted. So we we have discontinued our practice of having pilots do the database update. If we anticipate needing an update while the aircraft is on the road, we either bring a mechanic with us or have the mechanic airline to a convenient stop on the trip.

I've redacted the FAA manager's name and number because I don't think inundating him with email and phone calls is going to change anything. He is, after all, just interpreting the regulation. Looking at the regulation, I think he is right. The only way to change this is through your manufacturer.

Hello Capt. XXX,

Unfortunately, you are incorrect about a pilot being able to load the database on your G450. The pertinent regulation is 14 CFR section 43.3 (k), which reads:

(k) Updates of databases in installed avionics meeting the conditions of this paragraph are not considered maintenance and may be performed by pilots provided:

(1) The database upload is:

(i) Initiated from the flight deck;

(ii) Performed without disassembling the avionics unit; and

(iii) Performed without the use of tools and/or special equipment.

(2) The pilot must comply with the certificate holder's procedures or the manufacturer's instructions.

(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.

A laptop is considered special equipment as highlighted above. The rule is intended to permit pilot loading of databases in installed systems that accept media such as SD cards, flash drives, etc. Use of any external, uninstalled device such as dataloaders, laptops, etc. is prohibited by (iii) above.

Best regards,

Manager, Avionics Branch, AFS-360
Aircraft Maintenance Division
Federal Aviation Administration

References

14 CFR 43, Title 14: Maintenance, Preventative Maintenance, Rebuilding, and Alteration, Federal Aviation Administration, Department of Transportation

Gulfstream G450 Maintenance Manual, Revision 18, Dec 12, 2013

Revision: 20180410
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