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Logbook entry for GPS database updates. Update

The FAR was updated in 2012 and I didn’t notice. The new rule still lets the pilot update the database but does not require a logbook entry since maintenance in not performed.

§43.3 Persons authorized to perform maintenance, preventive maintenance, rebuilding, and alterations.
(k) Updates of databases in installed avionics meeting the conditions of this paragraph are not considered maintenance and may be performed by pilots provided:

(1) The database upload is:

(i) Initiated from the flight deck;

(ii) Performed without disassembling the avionics unit; and

(iii) Performed without the use of tools and/or special equipment.

(2) The pilot must comply with the certificate holder’s procedures or the manufacturer’s instructions.

(3) The holder of operating certificates must make available written procedures consistent with manufacturer’s instructions to the pilot that describe how to:

(i) Perform the database update; and

(ii) Determine the status of the data upload.

An owner may update the database of a panel-mounted GPS because it falls under preventive maintenance.
14 CFR Appendix A to Part 43 —Major Alterations, Major Repairs, and Preventive Maintenance

(c) Preventive maintenance. Preventive maintenance is limited to the following work, provided it does not involve complex assembly operations: …
(32) Updating self-contained, front instrument panel-mounted Air Traffic Control (ATC) navigational software data bases…

14 CFR § 43.9 requires maintenance record entries for preventive maintenance.

(a) Maintenance record entries. Except as provided in paragraphs (b) and (c) of this section, each person who maintains, performs preventive maintenance, rebuilds, or alters an aircraft, airframe, aircraft engine, propeller, appliance, or component part shall make an entry in the maintenance record of that equipment containing the following information:

(1) A description (or reference to data acceptable to the Administrator) of work performed.

(2) The date of completion of the work performed.

(3) The name of the person performing the work if other than the person specified in paragraph (a)(4) of this section.

(4) If the work performed on the aircraft, airframe, aircraft engine, propeller, appliance, or component part has been performed satisfactorily, the signature, certificate number, and kind of certificate held by the person approving the work. The signature constitutes the approval for return to service only for the work performed.

So to summarize, updating the database on a panel mounted GPS is considered preventive maintenance and the regulations require an entry in the maintenance record of that equipment and “The signature constitutes the approval for return to service only for the work performed.”

Based on these requirements I wondered if anyone actually completes a logbook entry each month when updating the nav database on their GPS. I posted the question to the CPA forum and got some interesting answers. Some people do update the aircraft logs and others keep a piece of paper in the aircraft with the most recent date of update. While it’s fairly clear when the GPS is turned on if the database is current, that’s not good enough for compliance with the regs since there is no signature and date for when the maintenance was performed. (Likewise the date of the last VOR check that is recorded by the Garmin SL30 is useful information, but does not satisfy the requirement since there is no signature.)

David Bunin clarified that:
“Okay, first of all, the regulations NEVER say LOGBOOK. They say ‘maintenance records’. That could be anything.”

My take-away is that a separate logbook for that piece of equipment can be kept in the plane for recording the database updates. The logbook becomes part of the maintenance records for the aircraft.

I already have a logbook for recording VOR checks that I keep in the plane and I have started logging the updates to the database in it as well.

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