Database Updates by Pilots

Normal Procedures

Eddie sez:



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Photo: C.W. Gilpin mechanic's license, 1928, The Davis-Monthan Aviation Field Register
Click photo for a link to the Web Site

Can you, the pilot, perform the database update on your airplane without running into trouble with the local FAA? Well it depends. It seems if it is a matter of plugging in a USB and hitting a switch in the cockpit you are okay. In my airplane it involves a laptop and for that reason, I cannot. Read on . . .

Everything here is from the references shown below, with a few comments in an alternate color.

Last revision:

2020-07-10

What the Regulation Says

[14 CFR 43, §43.3(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.

The FAA Clarifies

You might be thinking that subparagraph (iii) above means oscilliscopes, soldering irons, and an iron lung machine. Me too! Therefore, we pilots can do the update if all we need is a consumer grade laptop. Not so. I asked someone at Guflstream who said "of course you can!" But they were worried enough about it to call a lawyer who called the FAA. Oh well. . .

From: [Redacted]@faa.gov
Sent: Tuesday, September 5, 2017 11:22
To: Customer XXX
Subject: RE: Database Updating

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, flashdrives, etc. Use of any external, uninstalled device such as dataloaders, laptops, etc. is prohibited by (iii) above.

Please let me know if I can be of further assistance.

Best regards,

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

Can a pilot be "trained" for the task?

You might be told and/or asked by your organization that you, a pilot, can be trained by your mechanic/engineer and you magically become a mechanic authorized to do the database update while on the road. I thought this might be a good option until I paged up from the 14 CFR 43 paragraph quoted above. Here is what I found:

[14 CFR 43

(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.

So what is Part 65? That is the "Certification: Airman Other Than Flight Crewmembers" part that covers air traffic controllers, aircraft dispatchers, mechanics, repairmen, and parachute riggers. In other words, it is like Part 61 for pilots. Saying a pilot can be informally and quickly trained to qualify without a license is like saying you can instruct your mechanic to fly the airplane and have him or her do that without a license.

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