Log your GPS database updates

Skylane81E said:
Intent:

Anti corrosion spray.

Check your MM and washing/waxing will probably be found in the "Servicing" section.
Click to expand...
If the FAA made any effort to be logical, replacing/updating GPS databases ought to fall into the "servicing" category as well. AFaIK item #32 was added to part 43 appendix A to sanction pilot replacement of the DB cartridge that plugged into the rear of the KLN90 GPS and/or it's LORAN ancestor, said replacement requiring the removal of the entire navigator from the panel. And it's pretty clear that whoever wrote that text didn't really understand microprocessor controlled avionics and their ability to validate database contents. IME it's easier to make a serious mistake wiping bugs off the airplane or putting fuel in the tanks than when swapping DB cards in a GPS and the latter is even self documenting, at least as far as the DB's currency goes. This really ought to require no more recordkeeping than entering flight plans.
 
gismo said:
If the FAA made any effort to be logical, replacing/updating GPS databases ought to fall into the "servicing" category as well. AFaIK item #32 was added to part 43 appendix A to sanction pilot replacement of the DB cartridge that plugged into the rear of the KLN90 GPS and/or it's LORAN ancestor, said replacement requiring the removal of the entire navigator from the panel. And it's pretty clear that whoever wrote that text didn't really understand microprocessor controlled avionics and their ability to validate database contents. IME it's easier to make a serious mistake wiping bugs off the airplane or putting fuel in the tanks than when swapping DB cards in a GPS and the latter is even self documenting, at least as far as the DB's currency goes. This really ought to require no more recordkeeping than entering flight plans.
Click to expand...
As I told Dan a long way back up this thread, Part 11 of the FAR's provides you the process to petition for that change, and the PoA website is not part of that process. So for all you folks who don't like this rule, stop wasting your time posting your complaints here and start using your time productively on a petition for rulemaking.
 
John Collins said:
The wording for the record requirements is ambiguous. I intend to write to support the change, but some of the wording needs to be cleaned up.
Click to expand...
From what I read, the proposed change simply deletes part 43 Appendix A.c.32 (updating databases). In my comment I suggested that in addition to the change they have the Chief Counsel provide an opinion that clearly states any pilot (operator, etc) can perform this task and that no logging is required. The only other options for them I can see are (1) creating another section in Appendix A called "Servicing" which has a non-inclusive list of the kinds of things that don't require logging such as updating databases, adding fuel, putting air in tires, etc. or (2) adding database updating to the list of privileges for pilots in part 61.
 
The preventative maintence section aka Appendix A of part 43 has been so perverted by the FAA its discusting.

It is a list of things that you can remove, adjust, modify (ex data) and reinstall. Simple servicing was never ment to be an infraction. But some inspectors will twist any rule they can and use it to its fullest extent.

The FAA needs to catch up with the current state of technology when it comes to these aircraft.
 
gismo said:
From what I read, the proposed change simply deletes part 43 Appendix A.c.32 (updating databases). In my comment I suggested that in addition to the change they have the Chief Counsel provide an opinion that clearly states any pilot (operator, etc) can perform this task and that no logging is required. The only other options for them I can see are (1) creating another section in Appendix A called "Servicing" which has a non-inclusive list of the kinds of things that don't require logging such as updating databases, adding fuel, putting air in tires, etc. or (2) adding database updating to the list of privileges for pilots in part 61.
Click to expand...

This is from the text of the new rule:

§ 43.3 Persons authorized to perform maintenance, preventive maintenance, rebuilding, and alterations.​
* * * * *
(k) The holder of a pilot certificate issued under part 61 of this chapter may perform updating of self-contained, front-instrument panel-mounted and pedestal-mounted air traffic control (ATC) navigational system databases (excluding those of automatic flight control systems, transponders, and microwave frequency distance measuring equipment (DME), and any updates that affect system operating
software) provided—
(1) No disassembly of the unit is required;
(2) The pilot has written procedures available to perform and evaluate the
accomplishment of the task; and
(3) The database is contained in a field-loadable configuration and imaged
on a medium, such as a Compact Disc Read-Only Memory (CD–ROM),
Synchronous Dynamic Random-Access Memory (SDRAM), or other nonvolatile memory that contains database files that are non-corruptible upon loading, and where integrity of the load can be assured and verified by the pilot upon completing the loading sequences.
(4) Records of when such database uploads have occurred, the revision number of the software, and who performed the upload must be maintained.
(5) The data to be uploaded must not contain system operating software​
revisions.
I have several problems with k(4): first, the format of the record is inconsistent with the logging requirements in 91.417 as different data is required. Second, there is no expiration date for keeping the records once the work has been superseded. Third, it refers to database uploads in the first part of the sentence, but later requires that the revision number of the software be part of the record. What software are they talking about? I presume they mean the database revision level or effective date, and if this is what they mean, they should say that. I also would challenge the requirement that the record be made in the first place, especially if the equipment maintains the current database revision and effective dates electronically, which can be verified by the pilot prior to flight and can be inspected at any time.

I would recommend that section k(4) be rewritten to:

(4) Records of when such database uploads have occurred, the revision number or effective date of the database, and who performed the upload must be maintained. These records shall be kept for one year or until the database update has been superseded. If the equipment maintains an electronic record of the effective date of the database, this record need not be made.​

As far as k(5) is concerned, I would add "unless authorized by the administrator" at the end to allow for the possibility that a software provider is able to convince this work can be done safely in the future.
 
n20junkie said:
The preventative maintence section aka Appendix A of part 43 has been so perverted by the FAA its discusting.

It is a list of things that you can remove, adjust, modify (ex data) and reinstall. Simple servicing was never ment to be an infraction. But some inspectors will twist any rule they can and use it to its fullest extent.

The FAA needs to catch up with the current state of technology when it comes to these aircraft.
Click to expand...

Just bitching about it is not constructive. You now have a chance to comment on the NPRM and influence the outcome. The last time around, when items 31 and 32 were added to preventive maintenance, there were no comments on the logging requirement, so we have had them since 1997, the last 14 years.
 
Joe B said:
http://www.faa.gov/regulations_policies/rulemaking/recently_published/

See the NPRM entitled "Pilot Loading of Navigation and Terrain Awareness Database Updates". Gismo nailed it.

You just think .gov doesn't pay attention to what's going on here on the Blue Board.... :D
Click to expand...
Did you read it fully? Including this:
(4) Records of when such database
uploads have occurred, the revision
number of the software, and who
performed the upload must be​
maintained.
Click to expand...
All that change does is allow the pilots of Part 135/121 aircraft to do what Part 91 pilots have been doing all along. It does not eliminate the requirement for a record of the updates (although it does relax where/how you have to record the updates from the 43.9 standard).
 
Ron Levy said:
It does not eliminate the requirement for a record of the updates (although it does relax where/how you have to record the updates from the 43.9 standard).
Click to expand...

Ron, it creates a new type of entry and it isn't clear to me that it is covered by 91.417 which specifies retention of one year or until superseded.
 
Oh goodie -- we have a new rule that is as complex as the old rule! Yay!

:goofy:

How about this? If it's a VFR DB, there is no update requirement, therefore any changes to the DB are not logged since they are non-essential.

IFR DB updates are evident on startup, which should be sufficient as a "log."

But what sense would that make?

:dunno:
 
dmccormack said:
How about this? If it's a VFR DB, there is no update requirement, therefore any changes to the DB are not logged since they are non-essential.
Click to expand...
How about this? If the plane is not IFR certified, the AI, turn coordinator, and VOR are not required for flight, so any tinkering to those instruments is not logged since it is, as you put it, "non-essential." These actions all constitute some form of "maintenance" subject to Part 43, so where would you draw the line on which ones must be logged? The FAA's answer in the name of simplicity is "all," so where else would you draw that line?
 
Ron Levy said:
How about this? If the plane is not IFR certified, the AI, turn coordinator, and VOR are not required for flight, so any tinkering to those instruments is not logged since it is, as you put it, "non-essential." These actions all constitute some form of "maintenance" subject to Part 43, so where would you draw the line on which ones must be logged? The FAA's answer in the name of simplicity is "all," so where else would you draw that line?
Click to expand...

How about this? DB updates to handheld GPS must be logged too.

Where do we draw the line?
 
Bob Noel said:
How about this? DB updates to handheld GPS must be logged too.
Click to expand...
Why? It's not part of the aircraft.

Where do we draw the line?
Click to expand...
The FAA draws the line at what is installed in the aircraft, and that's a pretty easy one for us to understand and them to justify. If you and Dan can come up with a better way to draw that line (and one which will not result in even more trouble figuring what must be logged), please share it with us.

And since this is the third time I've asked you guys to come up with a better idea, and so far I've been ignored, if you ignore this one, I'll know it is pointless to continue responding.
 
Ron Levy said:
Why? It's not part of the aircraft.

The FAA draws the line at what is installed in the aircraft, and that's a pretty easy one for us to understand and them to justify. If you and Dan can come up with a better way to draw that line (and one which will not result in even more trouble figuring what must be logged), please share it with us.

And since this is the third time I've asked you guys to come up with a better idea, and so far I've been ignored, if you ignore this one, I'll know it is pointless to continue responding.
Click to expand...

Easy to understand? absolutely. But easy to understand isn't a justification.

Easy to justify? Nope.

What possible hazards would be introduced if DB updates to installed VFR GPS were not logged? Which of these would not also be possible with a DB update to a handheld VFR GPS?

In other words, what problem is being addressed by the requirement to log GPS updates?


btw - I probably have a better understanding of the airworthiness certification process than the average owner/pilot, especially wrt software aspects of the process as well as the certification of navigation databases. So feel free to get as technical as you want in attempting to justify logging of VFR GPS DB updates to installed equipment.
 
Ron Levy said:
Why? It's not part of the aircraft.

The FAA draws the line at what is installed in the aircraft, and that's a pretty easy one for us to understand and them to justify. If you and Dan can come up with a better way to draw that line (and one which will not result in even more trouble figuring what must be logged), please share it with us.

And since this is the third time I've asked you guys to come up with a better idea, and so far I've been ignored, if you ignore this one, I'll know it is pointless to continue responding.
Click to expand...

I guess you ignored this post:

dmccormack said:
How about this? If it's a VFR DB, there is no update requirement, therefore any changes to the DB are not logged since they are non-essential.

IFR DB updates are evident on startup, which should be sufficient as a "log."
Click to expand...

You see, in the computer (i.e. "real") world, we distinguish between code and data.

We don't log a software update every time Mrs. Johnson types a memo.
 
dmccormack said:
I guess you ignored this post:
Click to expand...
No, I didn't. In fact, it was that post which led me to ask the question originally. Since you clearly aren't going to answer the question and tell us how you would draw the regulatory line between what maintenance-type actions should/need not be logged, I guess there's no point in continuing.
 
Richard said:
As a side note, it appears your reference to the AIM is evidence the AIM is in fact regulatory. Some persons have debated that.:(
Click to expand...
:yes:

Same thing for rules regarding IFR GPS use in lieu of DME or any other ground based navaide, you're not going to find them anywhere in the FARs.
 
Ron Levy said:
Why? It's not part of the aircraft.

The FAA draws the line at what is installed in the aircraft, and that's a pretty easy one for us to understand and them to justify. If you and Dan can come up with a better way to draw that line (and one which will not result in even more trouble figuring what must be logged), please share it with us.

And since this is the third time I've asked you guys to come up with a better idea, and so far I've been ignored, if you ignore this one, I'll know it is pointless to continue responding.
Click to expand...
I realize you're talking about avionics, but where's that line WRT adding fuel to fuel tanks, oil to crankcases, alcohol to alcohol tanks, and air to tires? I've never heard of any requirement to log any of those activities yet I also never seen anything that draws a line between adding oil and changing oil (which is mentioned in part 43 Appendix A and must be logged).

I do agree that the current regs require DB update logging but I still maintain that there's no more point in logging them than there would be for logging refueling.
 
Last edited:
I'd suggest that the FAA could remove all reference to the DB update logging and let the GPS manufacturer take care of it in their ICA manual. They could specify who and how updates should be accomplished. This addresses Dans's beef with applyinh the rule to VFR GPSs.
Pilots still have the responsibility to verify the DB date prior to IFR operations.
 
gismo said:
I realize you're talking about avionics, but where's that line WRT adding fuel to fuel tanks, oil to crankcases, alcohol to alcohol tanks, and air to tires? I've never heard of any requirement to log any of those activities yet I also never seen anything that draws a line between adding oil and changing oil (which is mentioned in part 43 Appendix A and must be logged).
Click to expand...
Check your aircraft manual -- those are all defined as "servicing." And one big difference between adding and changing is the removal, replacement, and safety wiring of the oil sump drain plug as opposed to merely unscrewing and replacing the dipstick.

I do agree that the current regs require DB update logging but I still maintain that there's no more point in logging them than there would be for logging refueling.
Click to expand...
I try to avoid the "why's" or justifications of rules like this, and stick with teaching folks what the rule is and how to comply with it.
 
Ron Levy said:
Check your aircraft manual -- those are all defined as "servicing." And one big difference between adding and changing is the removal, replacement, and safety wiring of the oil sump drain plug as opposed to merely unscrewing and replacing the dipstick.
Click to expand...

But isn't adding oil "lubrication" as in Appendix A of Part 43?

Appendix A
(c) (6) Lubrication not requiring disassembly other than removal of nonstructural items such as cover plates, cowlings, and fairings.

So if you add a quart of oil, you should be logging it? I know we do for our 135 bird but that is more to comply with our GMM than anything in 43.
 
Ron Levy said:
Check your aircraft manual -- those are all defined as "servicing."
Click to expand...
That may be true but aside from the limitations section, the POH isn't regulatory so it really doesn't matter what's listed there as "servicing". And in my Baron's POH, the "servicing" section shows all the lubrication tasks, most of which do require logging and IIRC there's no mention at al about adding fuel in that section.

And one big difference between adding and changing is the removal, replacement, and safety wiring of the oil sump drain plug as opposed to merely unscrewing and replacing the dipstick.
Click to expand...
I didn't mean to imply otherwise, rather I was comparing DB updating with adding/checking oil vs oil changes which are more comparable to operating software updates (which I do think should be logged).

I try to avoid the "why's" or justifications of rules like this, and stick with teaching folks what the rule is and how to comply with it.
Click to expand...
Which is as it should be when you're CFIIing. But I see no reason why you shouldn't question (vs ignore) stupid rules on your own.
 
Ron Levy said:
[snip]
And since this is the third time I've asked you guys to come up with a better idea, and so far I've been ignored, if you ignore this one, I'll know it is pointless to continue responding.
Click to expand...

In determining whether some is "better", we need to know the criteria that is appropriate for judging whether something is better. It seems to me that one aspect that is necessary for an idea to be "better" is that it doesn't introduce new problems. So I'll ask again:

What possible hazards would be introduced if DB updates to installed VFR GPS were not logged? Which of these would not also be possible with a DB update to a handheld VFR GPS?

In other words, what problem is being addressed by the requirement to log GPS updates?
 
Bob Noel said:
What possible hazards would be introduced if DB updates to installed VFR GPS were not logged? Which of these would not also be possible with a DB update to a handheld VFR GPS?

In other words, what problem is being addressed by the requirement to log GPS updates?
Click to expand...

None save bureaucratic fastidiousness.
 
Ron Levy said:
Check your aircraft manual, which will describe addition of oil as "servicing."
Click to expand...

You mean to imply that "servicing" an aircraft is not, in fact, preventive maintenance if the item you are "servicing" is found in 43 Appendix A?

So if Garmin (as an example) changed their GNS400/500-series supplements to show updating the database as "Servicing" the unit, then we could skip the logging?
 
straightwingedjetsrule said:
You mean to imply that "servicing" an aircraft is not, in fact, preventive maintenance if the item you are "servicing" is found in 43 Appendix A?
Click to expand...
I'm not implying that -- the FAA is saying that.
Maintenance means inspection, overhaul, repair, preservation, and the replacement of parts, but excludes preventive maintenance.

Preventive maintenance means simple or minor preservation operations and the replacement of small standard parts not involving complex assembly operations.
Click to expand...
...and Appendix A to Part 43 tells us what is defined as "preventive maintenance," and adding oil (as opposed to an oil change which requires removing, replacing, and safety-wiring the drain plug), isn't on that list.

So if Garmin (as an example) changed their GNS400/500-series supplements to show updating the database as "Servicing" the unit, then we could skip the logging?
Click to expand...
I suppose that would be true if the FAA didn't specifically define it as "preventive maintenance" in Part 43, and they're in the process of removing it from that list for other reasons (specifically, so pilots of commercial operators can do it themselves as opposed to requiring a maintenance person, since pilots can't do preventive maintenance in commercial operations). However, that proposed change still specifically requires keeping a record of the update and the operational check of the system after the update (which I think is their main concern, not the update itself), so nothing Garmin writes can overrule that.
 
Ron Levy said:
However, that proposed change still specifically requires keeping a record of the update and the operational check of the system after the update (which I think is their main concern, not the update itself), so nothing Garmin writes can overrule that.
Click to expand...

Hunh? Where is that requirement for a VFR GPS DB? Is the owner supposed to fly over and spot check each waypoint?

Sorry, Ron, but you're revealing a lack of expertise on how databases work.....
 
dmccormack said:
Hunh? Where is that requirement for a VFR GPS DB?
Click to expand...
In 14 CFR 43, Aopendix A, item 32, which makes no differentiation between IFR and VFR units.
Is the owner supposed to fly over and spot check each waypoint?
Click to expand...
I suppose that depends on what it says in the manuals for that unit, but for the GNS400/500 series, that's not required.
Sorry, Ron, but you're revealing a lack of expertise on how databases work.....
Click to expand...
:rofl:
 
Ron Levy said:
In 14 CFR 43, Aopendix A, item 32, which makes no differentiation between IFR and VFR units.
I suppose that depends on what it says in the manuals for that unit, but for the GNS400/500 series, that's not required.
Click to expand...

Do you understand the difference between data, code, and firmware?

:confused:

Perhaps if you did, you'd understand a database update is not replacing an oil filter.

And you're adding requirements -- there is no requirement to log a "operational test." None.
 
dmccormack said:
Do you understand the difference between data, code, and firmware?

:confused:

Perhaps if you did, you'd understand a database update is not replacing an oil filter.
Click to expand...
I do indeed, Dan. However, per 14 CFR Part 43, Appendix A, they are both "preventive maintenance" and both must be logged IAW that Part.
And you're adding requirements -- there is no requirement to log a "operational test." None.
Click to expand...
Homework for Dan:
1. Go to the FAA RGL Home page.
2. Select Code of Federal Regulations.
3. Go to Part 43.
4. Go to Appendix A.
5. Go to section (c).
6. Go to item (32).
7. Copy item (32) here.
8. Highlight the last sentence in bold and underline.
9. Read the bold and underlined part aloud several times,
10. Apologize for the post quoted above.

Have a nice day, Dan,
 
Last edited:
Ron Levy said:
I do indeed, Dan. However, per 14 CFR Part 43, Appendix A, they are both "preventive maintenance" and both must be logged IAW that Part.
Homework for Dan:
1. Go to the FAA RGL Home page.
2. Select Code of Federal Regulations.
3. Go to Part 43.
4. Go to Appendix A.
5. Go to section (c).
6. Go to item (32).
7. Copy item (32) here.
8. Highlight the last sentence in bold and underline.
9. Read the bold and underlined part aloud several times,
10. Apologize for the post quoted above.

Have a nice day, Dan,
Click to expand...


For a VFR Database, Ron?

Check again.
 
You must log in or register to reply here.
Back
Top