Requirements for logging GPS database updates

[RobertGary1]

Today its not just GPSs but my nav/com and even my attitude indicator have database subscriptions from Garmin. At one point I heard you had to log each update in the aircraft logs. But I've not heard that recently. I think you could make the argument that the database record on the device would suffice. What is the current FAA legal status on logging?

 

-Robert

[RobertGary1]

Oops, a second attempt at Google was more fruitful..

 

"

Several commenters, including AOPA and NetJets, were concerned about the requirement for the pilot to record each update in a maintenance logbook. AOPA expressed concern that the NPRM proposed a requirement that would create a second recordkeeping requirement and that the return to service maintenance entry required by § 43.7 would need to be completed by “qualified personnel.” NetJets recommended that the FAA specifically state in the final rule preamble that no aircraft maintenance entries or signatures are required when pilots perform aeronautical database updates. We have considered the comments and agree that it is unnecessary for the pilot to make a record of the update. Recordkeeping requirements for the pilot have been eliminated. The current regulations do not require pilot-owners to record each update in a maintenance logbook, and the absence of such a requirement has not been problematic."

 

https://www.federalregister.gov/documents/2012/11/29/2012-28845/pilot-loading-of-aeronautical-database-updates

 

-Robert

[midlifeflyer]

Even better than Google and the Final Rule commentary in the Federal Register, why not check the regulation itself? FAR 43.3(k).

[RobertGary1]

14 hours ago, midlifeflyer said:

Even better than Google and the Final Rule commentary in the Federal Register, why not check the regulation itself? FAR 43.3(k).

Maybe I missed it but where in 43.3(k) does it say this is the only maintenance item that is exempt from a logbook entry?

-Robert

[EricJ]

18 minutes ago, RobertGary1 said:

Maybe I missed it but where in 43.3(k) does it say this is the only maintenance item that is exempt from a logbook entry?

-Robert

It says it is not considered maintenance, therefore no maintenance entry is required.

[midlifeflyer]

5 minutes ago, EricJ said:

It says it is not considered maintenance, therefore no maintenance entry is required.

Yep.

"Updates of databases in installed avionics meeting the conditions of this paragraph are not considered maintenance..."

[jlunseth]

I don’t remember how the change was done, but I do remember that the logging requirement changed. In the first few years after GPSs came into common use we were required to log each update, had to be signed and dated. That was eliminated quite a few years ago. The rationale was that the date of the current database is displayed in the GPS when it starts up, so there was no longer a need for a written log of changes. May have been an AC but don’t really remember.

[PeteMc]

Firmware updates need to be done by an Avionics shop.   Database updates can be done by the pilot (or anyone). 

 

[jlunseth]

19 minutes ago, PeteMc said:

Firmware updates need to be done by an Avionics shop.   Database updates can be done by the pilot (or anyone). 

 

Yes, true.

[jlunseth]

Seek and ye shall find.

14 CFR 43.3(k)

I vaguely remember some people asking if “initiated from the flight deck” and “without the use of special equipment” meant you could not take the datacard out of the GPS and put it in a computer. The reaction was pretty much, oh, come on, that is how everyone is doing it, that is what they meant in the reg. Now, of course, it can be uploaded wirelessly, but that doesn’t change anything, you can take the datacard into the FBO, load the data on the card, and then take the card out to the plane and put it in. 

On the issue of firmware/software updates, 43.3(k) is limited to databases. On the issue of logging, the comments during the rule process (see below) make clear that the amendment to the rule is intended to make database updating without the use of special tools a non-maintenance task which is not regulated, and therefore logging is not necessary:

"Updating aeronautical databases will not be regulated as maintenance on specified equipment in accordance with the requirements set forth under the new paragraph (k) in § 43.3"

 

https://www.federalregister.gov/documents/2012/11/29/2012-28845/pilot-loading-of-aeronautical-database-updates