Logging GPS updates?

[Doug G.]

Just heard a FAA FAAST representative say that if an owner updates their GPS database it needs to be logged in your airframe logbook as a primary avionics instrument. ??

Doug

[coppercity]

I could see that for an IFR Certified GPS being used for enroute and approach navigation in IMC, but seems overkill for a VFR only GPS.

[Doug Hereford]

dggrant,

The task that you describe would very likely be defined as preventive maintenance (ref FAR 43 app A ©(32). As a pilot/sport pilot, you are allowed to perform this task (ref. FAR 43.3(g)), however, before you can legally approve the aircraft for return to service, you must make an aircraft maintenance record entry as required by FAR 43.5(a). The entry must include the items listed in FAR 43.9(a).

It is irrelevant as to whether the aircraft is operated VFR or IFR.

 

Doug Hereford

[Doug G.]

Doug, I assume the same would be true of any Dynon EFIS or EMS updates also.

Doug :-)

[Doug Hereford]

Doug,

Your question is getting a little trickier. Typically EFIS falls under instrumentation, and may not deal directly with navigation (of course it receives nav info from some other sources though). EMS falls under engine instrumentation. FAR 43 app. A (preventive maintenance) only allows for the updating of ATC navigational data bases, and limits which ones depending on the specific equipment to which they are attached. The answer to the original question still stands. If one updates software on any avionics equipment, it would either fall under the definition of preventive maintenance, or some combination of maintenance/alteration. In either case, a maintenance record entry would be required.

 

Since EFIS/EMS updates may not (probably don't) relate to navigational data bases, this task may not be preventive maintenance, and therefore a pilot/sport pilot is not legally able to approve the aircraft for return to service. I don't know your level of certification, so I can't say if you would or would not be authorized to do this. One really has to be careful here. If the update of an EFIS/EMS causes changes to callibrated instrumentation, this may fall under the definition of an instrument alteration or repair. For SLSA (which are maintained IAW part 43), any alteration or repair to an instrument must be performed by an appropriately rated repair station, or the manufacturer.

 

I realize this answer goes in two different directions, so just to be specific, yes, a maintenance entry is required for the EFIS/EMS update. Same regulatory references as my previous post.

 

Doug Hereford

[Doug G.]

At this point I am a sport pilot. Rainbow will change that in September at Oshkosh to sport pilot/LSRM-A.

Doug

[DocRon]

Hi Guys,

 

I was with Doug at that Safety Seminar and I further queried this FAA Inspector about this item. It just doesn't seem right but, Doug(2), you've made it much clearer.

 

As with many things I've heard from the FAA that I don't understand, I take my right fist and thump my chest over my heart and say loudly "I HEAR AND OBEY!"

[S3flyer]

The logging of GPS updates does not apply to most of us in the LSA world since very few of us have what the FAA defines as panel mounted units. The Garmin X96's are handhelds not panel mount even if you have them in your panel in an AIr Gizmo. The applicable language: "Updating self-contained, front instrument panel mounted Air Traffic Control (ATC) navigational software....".

 

In reading the applicable language, though, if you decide you need to log the updates you are not required to do it in the aircraft/avionics log book. You could keep it in an excel document with a line per entry. Also, you only need to retain for 1 year which is about how often my Garmin gets updated (too $$$).

 

 

[Jim Meade]

Also, you only need to retain for 1 year which is about how often my Garmin gets updated (too $$).

 

 

What is the exact language? I'd thought it was one year or until superceded?

[S3flyer]

Jim -- you are correct. 91.417 states:

(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.

This is pretty interesting since each GPS update supersedes the prior. This implies that you only need to keep a record of the latest update which, it can be argued, that the GPS unit itself has this information (other than a signature). I'd suggest just printing out the latest receipt from Garmin (or whoever), enter the proper information and file it at home. Destroy the prior receipt on each new update.

[DocRon]

I spoke to this FSDO ASI again and he confirmed (after research) that the requirement is for IFR flight, not VFR. However, he said it was a good idea to do so as by documenting your updates it shows how dilligent and professional you've been when it comes time to sell or trade-up your aircraft.

 

I do see the logic here. The several times I've bought (or nearly bought) aircraft I've gone through the logs with a microscope (figuratively anyway:) The ASI was right, these entries during ownership do show you something about the seller and how he/she treated their aircraft. Little things like this stand out, therefore, I'm going to do it.

[Jim Meade]

Keeping a record you aren't required to have invites someone to use it against you. There is no up side to keeping it except this notional idea that the prospective buyer will know you performed a process on a timely basis. Can't you show the same thing by accurate logging of required functions?

[Roger Lee]

Hi Jim,

Being from the medical side of things for 30 years, not keeping good records will bite you in the butt far more than keeping good ones. If you do what is right they can't be used against you. The courts say if it isn't in writing you didn't do it and nothing you say will make a difference. I have seen it in court a bunch of times. Keeping good records will also keep your re-sale value up by $5k - $10k.

[Jim Meade]

Roger,

 

There is no question of the value of keeping good records where they are required. Implying that keeping unneeded records is part of keeping good records in not supported in my aviation experience. Of course, everyone can do as they wish, but it is not the norm in legacy aviaiton.

 

 

[Roger Lee]

Hi Jim,

Keeping poor records has cost some major airlines a pretty penny. The FAA or the court gets to decide what good records are, not you, so why leave yourself open trying to out guess what they want.Your right on, it isn't the norm and that's the problem. Once you've been to court a few times and watched what happens to people who keep poor records you will be cured forever. As an owner or mechanic that is the only thing that will save you.What are un-needed records exactly? Who decides if they are not needed? Too many things are left out of records out of fear, ignorance or laziness.I have seen it in court where a medic thought it was not needed to put something in his report because he does it every time. He put it in writing other times, but not this time, the ultimate sin in court. Pulled into court he can't prove he did it because it wasn't written down, regardless if he did it. He and the city lost big and I have seen it more than once. If you don't put it in I writing it wasn't done and that is legally is 100 times worse than keeping better than average records and is ten times easier to defend in court or prove to a buyer you really did do something. I have been seeing way too many planes come into the shop that the previous buyer said he did something, but wasn't in writing and the new owner believed them. Then I showed the new owner the seller wasn't telling the truth.

 

I have been in court more times than I can count over 30 years for both sides. As a matter of fact I have one more to go in Nov. from 5 years ago. I have to testify for both sides and my paperwork is more complete than both of theirs. That's really going to upset the plaintiff. Keeping very detailed records will almost always save you and almost never hurt you unless you lied.

[Jim Meade]

Roger,

 

We are in agreement on most of this, but in total disagreement on some parts so let's clarify that and then I'll drop it. Any readers can take any message from it they want and apply it as they choose. The bottom line is you are saying keep records that are not needed and I think people should think about that. I do not do it.

 

I am not saying don't keep complete records. If you do an annual and you want to write down the plug gap of each plug, go ahead and do so, even though I don't know of a single mechanic who does. But, you have to record the annual and if you like that level of detail you'll probably only aggravate the next mechanic who has to paw through it all to get to the good stuff.

 

What I am saying is that the FAA does not require nor does the industry expect you to keep VFR or portable GPS update logs. This is what I am talking about as an unnecessary record. We have an anecdote that one FSDO guy says "oh, that is a good idea because it shows you are professional". I say hogwash. It would show you were professional if you keep accurate, complete records of all maintenance work done and any other required or customary records. All it does when one keeps an unneeded record is show one is anal and that one is not sure of what is really important and what is not.

 

It's been suggested that if I buy an airplane, having these unneeded logs may persuade me that the seller is professional and diligent. What will persuade me that the seller is professional and diligent is if all required records are accurate, comprehensive and complete. I will look at those hard. If they are top notch, they will tell the story of the airplane. If they are not top notch, showing me records that didn't need to be kept at all makes me wonder why someone would do a good job where it wasn't required and less than a top job where it mattered. I would question the situation and while it may not affect my decision, it would hardly make me feel warm and fuzzy - "what, is the guy willing to do easy stuff he doesn't have to but not willing to do hard stuff that he should?" "Does this guy know what is required and what is not - did he do all the required stuff?"

 

To fly IFR, one must log IFR GPS data base updates and one must perform and log a VOR check within the last 30 days if using a VOR. The minimal information the FAA requires can be written on a cocktail napkin (that is not my metaphor, it is a common one used by those teaching this subject). It can be stuck in the glove box or anywhere it is available if demanded on the flight. When it is superceded, it proves nothing the FAA wants to know or requires you to show.

 

I'm not a big fan of bringing in outside examples such as your EMT or fire experience or my farming or military time - I think the best discussion is when the environment is kept to aviation, but if one is looking for a simile, many states require registration and proof of insurance be presented to an officer on demand. Where do we keep them? In the glove box (yes, we know they used to kept in a holder so they could be read through the windshield, but this was 50 years ago when it was discovered that thieves would assume that if the car was gone no one was home so they'd read a car registration through the windshield, then go rob the home - kind of reminds you of georeferencing your photos on Facebook, doesn't it?) So, the effective periods of the registration and proof of insurance often overlap. You get the new one before it's due and stick it in the glove box so now you have two. Then, you forget to take the old one out when it's past due so when you are stopped for speeding, is the officer impressed because you have two proofs of insurance? No. He could care less. One that is no good is of no help and one that is good is all one needs to satisfy him. In fact, showing an officer (or FAA inspector) an outdated document if you don't have the current one implies you know it is necessary but that you haven't complied. In a way, it's worse than if you pretended you didn't know it was needed at all. One may be ignorance, the other is deliberate.

 

Most people in legacy GA keep the VOR check (if they do it) in the glove box. Some use a little binder, some a form, some a scrap of paper. I used a note card. Same with the IFR GPS database upload record. The charter company I flew for had a 3-ring binder that stayed with each airplane and included many papers including VOR records because many different pilots flew the planes. This dispatch log book was the place we checked to make sure we were VOR current. When full, the sheet was destroyed in and another used.

 

The industry standard is that these records are not use for historical purposed. Roger, it seems like you are suggesting we keep unneeded records. You yourself make the point that keeping a record and then showing a gap infers to the court that the gap means you didn't do something (because when you did, you wrote it down). Now, take an unneeded record and make any simple, human mistake on it, such as a 7 for a 1, misplace or forget to enter one unneeded inspection, be off by a month or any of the other things we shouldn't do but slip up on, and we have provided someone with an opportunity to impugn our motives. They'll take the record we present unnecessarily and use it to find us at fault for things we are not responsible for. Then, they'll use that to impugn the rest of our record. 'Well, if he was sloppy here, he's sloppy there."

 

Again, taking an outside example, we are required to keep financial records for a certain period of time. If we get in a dispute with the IRS and offer records they don't have the authority to demand, they can use those extra records against us if they disagree with them.

 

Nearly all in aviation teach to not carry your aircraft or pilot logs in the aircraft because if you are ramp checked and have them, you are required to provide them. Now, did you really log those 3 TO/LDG within 90 days? You know you did them, but that was the day the baby was crying, the plane felt a little funny and you talked to the mechanic, the wife's mother was grumpy and you had to get the presentation ready for work. If the log book is in the plane when ramp checked, that mistake can hang you. If it is not there, it will have to be requested and you have time to review it for accuracy.

 

So, let's agree that all required records should be complete, accurate, comprehensive and meet the highest standards of the FAA.

 

I will continue to disagree with you that records one is not required to keep are of any benefit. That's all I have to say on the subject.

 

 

 

 

 

 

 

 

[S3flyer]

The FSDO is wrong. FAR 43 defines preventive maintenance and does not preface as to whether any item is IFR and VFR:

 

(32) Updating self-contained, front instrument panel-mounted Air Traffic Control (ATC) navigational software data bases (excluding those of automatic flight control systems, transponders, and microwave frequency distance measuring equipment (DME)) provided no disassembly of the unit is required and pertinent instructions are provided. Prior to the unit's intended use, an operational check must be performed in accordance with applicable sections of part 91 of this chapter.

 

Back to an earlier post, this also only applies to panel mount GPS units only (not Air Gizmos mounts, etc.).

 

I'm in violent agreement with both Jim and Roger in that we all should keep complete records:

 

So, let's agree that all required records should be complete, accurate, comprehensive and meet the highest standards of the FAA.

 

To each his own, but I would not permanently log any GPS update that was not required and, if I get an FAA-defined panel mount unit, I would only log what was required and would do so outside of my aircraft log books (similar to VOR checks). In my experience, going beyond the requirement with government regulations is at best neutral and often times turns out bad.

[Roger Lee]

If you have an incident in navigation or busting some air space and FAA has an investigation and you can't show you have the most up to date software or map info then you may have an issue. I log for all my customers any updates to the Dynon's or the GPS. I see no downside and only a plus for the owner to help them in jcase of any investigation and the owners commitment to keeping his plane up when it is sold to a new buyer. If the updates are done, but not logged and an investigation ensues then you will have to prove when and who and how they were updated. Why go there. If its in the logbook then the FAA will consider it a done deal.

I guess I'm a little on my soapbox here, only because I see so many planes come in and they have 2-4 lines in the logbook for the whole annual/100 hr. or I find work that was done or not and it isn't in the book. It just makes everyone's life more complicated than it needs to be.

[S3flyer]

Roger,

 

Fully agree that we need to keep complete logs as required by the FAA. FAR 43 requires preventive maintenace to be logged in the logbook that is appropriate for the part being serviced (airframe, engine, prop, etc.). These types of records are required to be held for one year or until superceded. I don't see the benefit of exceeding this requirement by permanently logging every GPS update. I would guess that most on the forum do not update their GPS's with every cycle. For VFR, it is neither required nor is it cost effective. I believe you may put yourself in a difficult situation in the courtroom explaining why you updated cycle #2 in 2010 but didn't in 2012. Is it relevant? No. Can an attorney spin this in a negative way and try to establish a pattern of sloppy maintenance? Yes. If there is only the single required entry, no pattern can be established other than you are compliant in maintenance and record keeping.

[Duane Jefts]

A good attorney can spin just about anything in a negative way. Both views have merit

 

I think everyone should just do what makes them comfortable along this topic line. Either way could be appropriate and defended against the Fed's if need be.

 

That's just my opinion.