On September 9, 2024, full compliance with the FAA’s Pilot Records Database (PRD) went into full effect, marking the simultaneous end of the Pilot Records Improvement Act (PRIA). In order to best help operators prepare and implement PRD compliance, AirTera formerly known as NATA Compliance Services (NATA CS) answered seven common questions on this topic.

Question 1. What are the FAA compliance requirements for pilot records?

There are four main items your operation needs to do to remain within FAA compliance:  

1. Retrieve pilot records from the PRD.
2. Request Drug & Alcohol History Checks from previous DOT-regulated employers the pilot-applicant worked for during the previous two years or more, per the operator’s policy.
3. Request a National Driver Register (NDR) records check.
4. Enter all new pilot records into the PRD within 30 days of creation.

Question 2. What are the penalties for not complying yet with the PRD?

The FAA published a Pilot Records Database Compliance Oversight Notice which stated that non-compliance with the PRD would be viewed as a willful act. Issues of non-compliance will be reviewed on a case-by-case basis with potential enforcement actings that range from a Letter of Corrective Action to civil penalties. The notice also indicates the FAA is electronically monitoring operators’ actions within the PRD.

Question 3. How do I instruct a pilot to grant their consent so their records can be accessed in the PRD?

The PRD has given pilots more control over their records. Before an operator can pull a pilot’s records, the pilot must log into the PRD and give the operator access. Pilots can also review their records within the database and decide the timeline for a future employer to retrieve them.

There may be times when a pilot is unable to access the PRD to grant access. When this occurs, they can complete FAA form 8060-14.

To further assist pilots in navigating the PRD, the FAA created a Pilot User Guide.

Question 4. We manage intermittent contract pilots the same as direct hire pilots. Is this the correct way for their records to be handled?

Yes. According to the FAA, reporting entities must provide the information to the PRD for any individual employed as a pilot, including contract pilots.

Question 5. Are part 91 operators required to comply with the PRD?

Some part 91 operators, such as fractional ownerships or air tour operators holding a part 91 Letter of Authorization, are required to comply with the PRD. However, the level of compliance is determined by your type of operation. Consult with your FAA Principal Inspector to determine your PRD compliance requirements.

Question 6. Will I still need to request Drug and Alcohol testing records and the National Driver Register Check in addition to PRD records?

Yes, because the PRD does not contain a full record of a pilot’s drug and alcohol testing history or driving records. Therefore, you are still required to request these two types of records in addition to what is pulled from the PRD. PRIA forms are no longer valid. If you use AirTera to request these, their new forms are available for download here.

Question 7. How do I set AirTera up as my PRD proxy?

AirTera offers PRD support services including records retrieval and entry. They also provide historic record entry if you are out of compliance with this regulation.

If you would like AirTera to act as your proxy within the PRD, start the process here.