The subject of the Pilots Record Database and its applicability for both Part 107 and COA pilots has created a thirst for more clarity. These FAQs below are a combination of information distributed by the FAA, and some are from the info I published here.
With the liability and complexity of yet another COA admin and reporting requirement, it makes no continued sense to fly under a COA when a simple call to the SOSC in an emergency gets a part 107 public safety operator the exact same operational flexibility a Part 91 PAO operator gets, then the cost-benefit analysis seems easier to make. The decision, of course, is in the hands of the qualified entity.
Does a PAO have to enter information on all their pilots into the PRD?
Answer: 14 CFR 111.200 requires the PAO to enter information for all pilots they employ, but PAO can delay reporting certain records until and unless they receive a request from a reviewing authority. Records that are not reported contemporaneously must be maintained for five years. If, however, the record memorializes a disciplinary action resulting in the permanent or temporary removal of the pilot from aircraft operations or separation from employment resulting in termination, the record must be reported to the PRD within 30 days of becoming final.
Who is the authorized responsible person (RP)?
Answer: That is the person appointed by the PAO who is responsible for the maintenance and upkeep of the data in the PRD
Can the RP delegate access to the PRD?
Answer: Yes, but they are still responsible for compliance with Part 111.
How does a RP get access to the PRD?
Answer: RPs must apply for access to the PRD. For instructions and information, click here.
What does a RP do with the PRD?
Answer: They will manage records and user accounts and be responsible for all actions taken within the PRD for a particular operator, entity, or trustee. They can also add or edit pilot records and review pilot records for new hires.
When does the PAO need to start entering data into the PRD?
Answer: PAO will begin reporting the applicable new pilot records within 30 days after 6/10/2022 unless they elect to maintain the records for five years and report only on request. Keep in mind some records must always be reported and don’t qualify for the report on request option.
What information is required in the PRD?
Answer: PAO must report training qualification and proficiency records, certain final disciplinary action records, or certain records concerning the separation of employment. See AC 120-68J for the specific list of what records are to be reported as well as more information about the PRD, the process, and the information required.
How long are the data to be maintained?
Answer: Records must remain in the database until either the FAA receives official notification of a pilot’s death or an FAA audit of the database indicates that 99 years have passed since the date of birth on record for a particular pilot.
Are all PAOs required to conduct a search in the PRD prior to allowing an employed pilot to fly for them?
Answer: No. Subpart B or Part 111 excludes PAO from the requirement. They may elect to review the records for new hires if they like. If a PAO department hires a pilot with a negative entry on the PRD and they never bothered to check, that could create issues when asked why they did not do a background check.
How does a PAO enter data on (non-FAA certificated) PAO self-certificated pilots?
Answer: The PRD requires an entry for all pilots employed by the PAO. PAO-certified pilots who do not possess a Part 107 or Part 61 certificate need alternate means of data entry, and this remains to be worked out due to the current technical limitations of the PRD.
We have a COA but only fly under Part 107, does the PRD still apply to us?
Answer: If you are conducting PAO (any flights that would be public aircraft operations) under a COA and you have pilots that are employed by the governmental agency all employed pilots would fall under the PRD even if they only flew Part 107 flights alone. The COA is not the trigger, Public Aircraft Operations are.
What should a PAO do if a negative issue turns up in the PRD search on one of their pilots?
Answer: That’s for the PAO to determine.
Where can a PAO go to get more information about PRD?
Answer: See the Federal Register / Vol. 86, No. 110 / Thursday, June 10, 2021, AC 120-68J, email firstname.lastname@example.org or read this.
Who are authorized reviewing entities?
Answer: Reviewing authorities are each operator holding an air carrier or operating certificate issued in accordance with part 119 and authorized to conduct operations under part 121, part 125, or part 135; operators holding an LOA issued under § 91.147; operators holding management specifications for a fractional ownership program under subpart K of part 91; operators conducting operations as a corporate flight department with two or more types rated aircraft or rotorcraft; entities conducting certain PAO operations; trustees in bankruptcy of any operator; pilots; and other persons who might access the PRD. Part 111 does not apply to any foreign air carrier or foreign operator of U.S. registered aircraft.
Does a pilot have to give consent to the reviewing authority before the pilot’s record can be reviewed?
Answer: Reviewing authorities must review a pilot’s records in the PRD prior to permitting the pilot to begin service as a required flight crewmember. In order to access and evaluate a pilot’s records, a reviewing entity must receive consent from that pilot.
If an otherwise qualified public aircraft entity chooses to only operate as a civil aircraft under part 107, do the PRD data entry requirements apply to that entity?
Answer: If they only fly under Part 107, the PRD requirements are not applicable. Part 111 does not apply to Part 107 operators.
Are any entities exempt from reporting to the PRD?
Answer: There is an exclusion for “operations conducted by any branch of the United States Armed Forces, National Guard, or reserve component of the Armed Forces.” Interestingly it does not explicitly name the Coast Guard and certainly is not clear about groups like the Civil Air Patrol, which is technically a separate 501(c)(3) non-profit that is an auxiliary of the Air Force, but not part of it.