Log your GPS database updates

[John Collins]

Log entries other than the VOR aircraft log record are not part of the ramp check check list or inspection requirements listed in 8900.1. I would not permit entry into the aircraft during a ramp inspection, nor would I immediately produce any maintenance entries at that point in time to preserve my rights. Remember that anything you say may be used against you.

The VOR aircraft log check by the pilot is not considered preventive maintenance and 91.171 d) states: Each person making the VOR operational check, as specified in paragraph (b) or (c) of this section, shall enter the date, place, bearing error, and sign the aircraft log or other record. I keep a separate VOR check log. This is one of the items that if kept in the aircraft, you are required to produce during a ramp check.

Even though I routinely check the VORs and make the aircraft log required, I haven't actually used them in IFR for the last four years, since my GNS530W was updated to software version 3.0 and was certified for sole means of IFR navigation. I only do this because there is always the possibility that WAAS may be unavailable and I would need them for navigation. WAAS being unavailable is extremely rare, although there was a complete outage that lasted 4 hours back on Oct 21. WAAS being unavailable is different from not being able to obtain vertical guidance on approaches.

 

[Bob Noel]

The rule isn't to log database updates. The rule is to log preventive maintenance [snip]

I understand the distinction.

I question why a database update to an installed VFR GPS is considered preventive mainenance.

 

[mantakos]

... I question why a database update to an installed VFR GPS is considered preventive mainenance.

Because making a specific exception would require a rational, thinking, well-functioning system.

So, instead, we're required to keep a piece of paper that has the date of when we last updated the GPS along with the name of who did it. Note that we're not required to maintain a log of all past updates, just a log of the most recent one. Note, of course, that a GPS self-identifies what version it has, so about the only thing this log entry provides is the name of the guy who did the update. This ensures, of course, that the person who did the update is properly authorized to do it, thus saving us from the danger of non-pilots performing GPS database updates.
-harry

 

[stapler101]

I should have included this in the original post: he is part 135 and this was found during his annual (??) audit. That may not be the exact terminology.
I at first assumed that this only applied to him because of his 135 but he insists that 43 applies to all.
As to the "punishment", he is fully expecting a fine. I don't know if that has been discussed or if he just expects it.
I did actually read the letter and it offers him a chance to reply and says that a final ruling will follow.

 

[dmccormack]

This ensures, of course, that the person who did the update is properly authorized to do it, thus saving us from the danger of non-pilots performing GPS database updates.
-harry

What happens with auto-updates? Does the guy in the IT department that hits' "Push" need to sign each logbook?

Exactly how many angels can dance upon the head of a pin? Have we resolved that one yet?

 

[TMetzinger]

I should have included this in the original post: he is part 135 and this was found during his annual (??) audit. That may not be the exact terminology.
I at first assumed that this only applied to him because of his 135 but he insists that 43 applies to all.
As to the "punishment", he is fully expecting a fine. I don't know if that has been discussed or if he just expects it.
I did actually read the letter and it offers him a chance to reply and says that a final ruling will follow.

Why wouldn't a DB update for a VFR GPS be considered maintenance? You changed something on a permanently installed part of the airplane. If it's not important enough to be considered maintenance, why did you bother to make the change?

If this came up in a part 91 operation, I'd think it was a BS thing to violate somebody on. But for a part 135 operator I expect the issue is that the operator's expected to know this stuff, and not logging the DB update raises the question "where ELSE are you not doing what you're supposed to?" I also think there's more to this story.

 

[dmccormack]

If this came up in a part 91 operation, I'd think it was a BS thing to violate somebody on. But for a part 135 operator I expect the issue is that the operator's expected to know this stuff, and not logging the DB update raises the question "where ELSE are you not doing what you're supposed to?" I also think there's more to this story.

Yep. See post #2

 

[poadeleted20]

However, I don't log every fuel sample, every oil check, every unbuttoning of the cowl, every tire pressure check, and every push into the hangar. I also don't log every recharge of my 12v SLA battery that powers my Sporty's SP-200 handheld transceiver. I don't log turning the radio on or off.

Correctly so, since none of those constitute any form of "maintenance" as defined in the FAR's.

In other airplanes I have flown, I logged VOR checks, Tach time each day, and 430W updates.

Again, correctly so (at least for the first third items).

I'm not questioning the propriety of logging. I'm questioning the rule that a VFR GPS database update must be logged.

It's pointless -- the VFR GPS screen could display Looney Tunes -- who cares? It's Visual Flight Rules.

Nevertheless, updating the database of an installed non-IFR database constitutes a form of "maintenance" just as much as tinkering with attitude indicator installed in an aircraft not certified for IFR operation, and thus must be logged. But as I said above, if you feel that maintenance performed on a component not required for the particular operation contemplated should not have to be logged, Part 11 tells you how to propose that change to Part 43.

 

[poadeleted20]

Log entries other than the VOR aircraft log record are not part of the ramp check check list or inspection requirements listed in 8900.1.

That is true. However, that fact does not prevent the Inspector conducting the Ramp Inspection from asking to see the aircraft maintenance records, and it does not provide you a legal excuse to refuse to produce them on the spot if they are in fact readily available. See below.

I would not permit entry into the aircraft during a ramp inspection, nor would I immediately produce any maintenance entries at that point in time to preserve my rights. Remember that anything you say may be used against you.

49 USC 44709 gives the FAA the right to inspect your aircraft and its records anywhere, any time, without probable cause or even reasonable suspicion.

TITLE 49--TRANSPORTATION

SUBTITLE VII--AVIATION PROGRAMS

PART A--AIR COMMERCE AND SAFETY

subpart iii--safety

CHAPTER 447--SAFETY REGULATION


Sec. 44709. Amendments, modifications, suspensions, and
revocations of certificates

(a) Reinspection and Reexamination.--The Administrator of the
Federal Aviation Administration may reinspect at any time a civil
aircraft, aircraft engine, propeller, appliance, design organization,
production certificate holder, air navigation facility, or air agency,
or reexamine an airman holding a certificate issued under section 44703
of this title.

While Inspectors are directed not to enter your aircraft without your presence, your refusal to permit entry on demand to perform that reinspection, or to present logbooks which are in your immediate possession, could be considered violations of Section 44709. IOW, they don't have the authority to enter your plane without your permission, but they have the power to punish you for not granting that permission.

In addition, the courts have held repeatedly and without exception that required records such as pilot logbooks and aircraft maintenance records do not enjoy protection under non-self-incrimination rights. See Administrator v. Jones and Administrator v. Weinstein for two examples.

[So long as the request itself is reasonable, in the sense that compliance presents no undue or inappropriate burden, the Administrator is not obligated to explain or establish why he wants or should be permitted to see the logbooks or other records he is authorized to review under regulations that impose no restrictions related to his motives.

The only right you have is for reasonable delay to produce records which are not immediately available. If the Inspector sees that bag labeled "Aircraft Logbooks" lying in the back seat, you can't say they aren't available. And if you lie about the location of the records, that opens a whole 'nother can of worms you really don't want opened.

 

[dmccormack]

Nevertheless, updating the database of an installed non-IFR database constitutes a form of "maintenance" just as much as tinkering with attitude indicator installed in an aircraft not certified for IFR operation, and thus must be logged.

But is a database update to a VFR GPS truly maintenance? After all, if I program my VFR GPS to play Space Invaders, what's the impact to the airplane or any flight under VFR?

 

[spinfire]

The issue isn't whether or not the GPS is "VFR" the issue is whether or not it is installed in the panel. If it's installed in the panel is is part of the aircraft and thus doing work on it is maintenance. It has nothing to do with it being IFR or VFR or anything of the sort.

 

[dmccormack]

The issue isn't whether or not the GPS is "VFR" the issue is whether or not it is installed in the panel. If it's installed in the panel is is part of the aircraft and thus doing work on it is maintenance. It has nothing to do with it being IFR or VFR or anything of the sort.

In the world of bureaucratic regulations, you're right. You insert something in the panel, you write it down. Period.

In a world of interconnected data producers and consumers, it's silly.

A GPS certified for IFR displays fixes and approaches et al that is critical to safety of flight. The database must be current as the various points may change and thus will impact the safety of flight. Inserting something and verifying what you have on board is what you expect and then documenting that somehow makes sense.

A VFR GPS database is different, in that under VFR your task is to see and avoid and navigate looking out the window. Every VFR GPS manual I've seen has a disclaimer about the GPS being "advisory" only.

Let's say you haven't updated the DB and the Datum changes and the airport is 3 miles west the impact to VFR flight is -- what?

If you think, "Oh no! I won't know where I am!" perhaps you need to revisit the intent and rules of VFR.

IMHO changing the setting in the Kollsman is closer to updating a VFR GPS DB -- it's merely content that is applied to an existing installation.

This entire point will be moot when on-board systems are updated via constant stream uplink.

 

[Jeanie]

Ok, logging updates not withstanding... What's this about placarding a VFR GPS as non IFR??? Hello, isn't that kind of redundant? The brand/model stands alone as obviously not IFR doesn't it? And if it's in a plane that isn't certified for IFR and couldn't be then it's just a GPS in the panel that is used for nav. like a VOR isn't it?
And if a placard is read where the heck do you put it, there isn't much space.

 

[John Collins]

Ok, logging updates not withstanding... What's this about placarding a VFR GPS as non IFR??? Hello, isn't that kind of redundant? The brand/model stands alone as obviously not IFR doesn't it? And if it's in a plane that isn't certified for IFR and couldn't be then it's just a GPS in the panel that is used for nav. like a VOR isn't it?
And if a placard is read where the heck do you put it, there isn't much space.

Can you quote the post where you read this "What's this about placarding a VFR GPS as non IFR???" I agree this makes no sense, but I could not find any post that claimed placarding a VFR GPS as non IFR.

The closest I could come to was to my post #14 where I responded to the question "There is a required placard that a GPS is VFR only if data not current, correct?". I answered "No. The placard that is required is for a GPS that is VFR Only or an IFR capable GPS that is installed as VFR Only".

 

[Let'sgoflying!]

excuse me.
Regarding the governments continued imposition of inane rules, and our fixation on them:

 

[JOhnH]

Help me understand the difference between:

What's this about placarding a VFR GPS as non IFR???"

and

"No. The placard that is required is for a GPS that is VFR Only

And here is another ignorant question: Do these rules apply to VFR pilots or only to IFR Rated pilots? I ask this realizing that the plane doesn't know who is flying, but do I need to log these updates if I don't have an IFR rating?

 

[JeffDG]

Help me understand the difference between:
and
And here is another ignorant question: Do these rules apply to VFR pilots or only to IFR Rated pilots? I ask this realizing that the plane doesn't know who is flying, but do I need to log these updates if I don't have an IFR rating?

Yes. You have to log any software updates that you do to any installed product. This includes firmware updates or database updates.

 

[JOhnH]

Yes. You have to log any software updates that you do to any installed product. This includes firmware updates or database updates.

ok, then theroetically speaking, if one has not been logging those updates, but starts now, then later gets inspected, are they still likely to get hung?

And can you log them retroactively in that separate log book that was mentioned? Or is there any other way to seek amnesty?

 

[AuntPeggy]

ok, then theroetically speaking, if one has not been logging those updates, but starts now, then later gets inspected, are they still likely to get hung?

And can you log them retroactively in that separate log book that was mentioned? Or is there any other way to seek amnesty?

And, must all the logs be retained? Can you discard all but the most recent?

 

[dmccormack]

ok, then theroetically speaking, if one has not been logging those updates, but starts now, then later gets inspected, are they still likely to get hung?

And can you log them retroactively in that separate log book that was mentioned? Or is there any other way to seek amnesty?

Wait -- if we're talking Part 91 and a VFR only GPS, what requirement is there to ever update the DB?

 

[JeffDG]

ok, then theroetically speaking, if one has not been logging those updates, but starts now, then later gets inspected, are they still likely to get hung?

And can you log them retroactively in that separate log book that was mentioned? Or is there any other way to seek amnesty?

Tell me, how would the feds know that you had not logged previous updates?

If they check today and see that the DB was updated last week, yet there's no log entry, they can show that there was an update without a log entry.

But if you updated it 6 months ago, without a log, and last week with a log, the evidence of the 6 month ago update no longer exists.

 

[JeffDG]

Wait -- if we're talking Part 91 and a VFR only GPS, what requirement is there to ever update the DB?

Bingo.

As long as you have your most recent update logged, they can't establish a violation.

 

[JeffDG]

And, must all the logs be retained? Can you discard all but the most recent?

I'd treat them like VOR checks. You need to show a VOR check in the last 30 days to use the VOR for IFR, right? Anything before that time is not required to be retained.

 

[mantakos]

And, must all the logs be retained? Can you discard all but the most recent?

FAR 91.417(b):

(b) The owner or operator shall retain the following records for the periods prescribed:

(1) The records specified in paragraph (a)(1) of this section shall be retained until the work is repeated or superseded by other work or for 1 year after the work is performed...​

If you update the database, that would "supersede" any prior updates, allowing you to discard the logs for those prior updates.
-harry

 

[Jeanie]

The closest I could come to was to my post #14 where I responded to the question "There is a required placard that a GPS is VFR only if data not current, correct?". I answered "No. The placard that is required is for a GPS that is VFR Only or an IFR capable GPS that is installed as VFR Only".[/QUOTE]

~~~~~. I misquoted it I suppose ... I have a non updated VFR only panel mount GPS in my plane. It is a VFR only GPS whether it is updated or not. Do I placard it as VFR only? Seems silly because the make and model is a VFR only GPS by design. Seems like labeling a shovel "shovel"

 

[skidoo]

On my G1000, each time I update the data base, I believe the MFD records the date and when it expires. Every time it boots up, it shows that record. In effect, is that not a log? Any reason that can not meet the requirements?

 

[gprellwitz]

On my G1000, each time I update the data base, I believe the MFD records the date and when it expires. Every time it boots up, it shows that record. In effect, is that not a log? Any reason that can not meet the requirements?

It doesn't indicate who did it.

Now, that raises the possibility of an aviation GPS prompting for your name and/or certificate number when it is updated. If we allowed electronic signatures, that may satisfy the logging requirement. But, AFAIK, there's no way to do that electronic signature portion at this time.

 

[Jim Logajan]

Since Part 43 doesn't apply to experimental aircraft, those owners and users don't need to worry about logging GPS database updates.

 

[denverpilot]

I'm all ready to break out the popcorn for the first GPS that connects to the cellular data network (on the ground of course) and updates itself.

That'll send the useless bureaucrats who need a piece of paper saying who stuffed an SD card into a device that already knows how to do a checksum against the data -- and does a better job checking that it's the data the manufacturer intended, than I can -- into a brand new tizzy of "safety enhancing" rule-making, I'm sure.

We pay for this service? We need to channel some Donald... "You're fired."

 

[poadeleted20]

Ok, logging updates not withstanding... What's this about placarding a VFR GPS as non IFR??? Hello, isn't that kind of redundant? The brand/model stands alone as obviously not IFR doesn't it? And if it's in a plane that isn't certified for IFR and couldn't be then it's just a GPS in the panel that is used for nav. like a VOR isn't it?
And if a placard is read where the heck do you put it, there isn't much space.

The installation paperwork tells you if such a placard is required and where it must be. The installer cannot legally sign off the installation unless any required placard is where it is supposed to be. Removing an installed placard (other than as part of removal or upgrade of the GPS) makes the aircraft legally unairworthy.

 

[dmccormack]

I'm all ready to break out the popcorn for the first GPS that connects to the cellular data network (on the ground of course) and updates itself.

It does already with an XM subscription -- data is being updated continually...

 

[timwinters]

Now, that raises the possibility of an aviation GPS prompting for your name and/or certificate number when it is updated. If we allowed electronic signatures, that may satisfy the logging requirement. But, AFAIK, there's no way to do that electronic signature portion at this time.

I have a friend, airline pilot, 182 owner, who logs his updates in the GPS itself. 430 I think. I don't know exactly how he does it but I think he just enters his name and cert # also.

Regarding the GPS updating requirement: I guess I'm surprised that so many seem to be surprised by this requirement. I used to just log the updates (along with the VOR checks) in my pilot's logbook but, about 4 years ago, I decided that was too messy so I just created a word doc with with the verbiage pre-entered. GPS on side one, VOR on side two. I keep these sheets on a clipboard in my flight bag.

Doc attached for reference.

 

[Bob Noel]

I'm all ready to break out the popcorn for the first GPS that connects to the cellular data network (on the ground of course) and updates itself.

That'll send the useless bureaucrats who need a piece of paper saying who stuffed an SD card into a device that already knows how to do a checksum against the data -- and does a better job checking that it's the data the manufacturer intended, than I can -- into a brand new tizzy of "safety enhancing" rule-making, I'm sure.

We pay for this service? We need to channel some Donald... "You're fired."

It won't be hard. The owner/operator will be required to log the action.

Simple.

It won't improve safety.

It won't help anything.

But it will make the OCD types happy.

 

[Skylane81E]

Just remember, as far as the FAA is concerned it's no different than changing your oil.

You log those right?

 

[Bob Noel]

What about waxing the aircraft? Does anyone log that?

 

[Skylane81E]

What about waxing the aircraft? Does anyone log that?

if it was on the list of "maintenance" items I would.

Not at anyone in particular:

Don't like it?
*****, moan complain. Write your congresscritter, AOPA, EAA FAA POTUS everyone.

 

[John Collins]

ok, then theroetically speaking, if one has not been logging those updates, but starts now, then later gets inspected, are they still likely to get hung?

And can you log them retroactively in that separate log book that was mentioned? Or is there any other way to seek amnesty?

Amnesty is not required. A history of previous maintenance records for preventive maintenance is not required to be kept after the work has been superseded and may be tossed out. You can't be forced to produce prior records that don't have to be kept under the regulations. So once you have made the current update entry, you can destroy any older copies. You don't need to lie about prior entries, they are not relevant, unless you lie about them.

 

[John Collins]

And, must all the logs be retained? Can you discard all but the most recent?

The most recent preventive maintenance records need to be kept for one year or until the work is repeated. Beyond this requirement, the records may be discarded. Note my choice of words, I did not call them logs as this tends to imply they are part of the aircraft permanent records, normally called the log books. See FAR 91.417 for details. It is well established that the maintenance records that are required are defined and what is required in the record, but not the form in which to keep them. If you want to keep yours on a block of marble rock and chisel them appropriately, that is acceptable. I keep my records in the form of sticky paper entries and decide which entries are required to go into the permanent records. I keep my database record on a simple piece of paper. I have the boiler plate information pre printed on the paper and only need to fill in the date, the effective date of the database, and my signature.

 

[Bob Noel]

if it was on the list of "maintenance" items I would.

"(10) Applying preservative or protective material to components where no disassembly of any primary structure or operating system is involved and where such coating is not prohibited or is not contrary to good practices."

 

[Skylane81E]

"(10) Applying preservative or protective material to components where no disassembly of any primary structure or operating system is involved and where such coating is not prohibited or is not contrary to good practices."

Intent:

Anti corrosion spray.

Check your MM and washing/waxing will probably be found in the "Servicing" section.