PRIA questions
 

First of all, I know there have been a lot of threads regarding this subject, and other threads where it has been discussed off topic also. If my question has already been discussed, feel free to direct me to the appropriate place.
That said:


I am filling out the PRIA (FAA 8060-11 and 8060-11A) paperwork for an upcoming interview. A separate copy of the form must be filled out for each flying job in the last 5 years.

So far all of my flying has been part 91. Some jobs I was not an employee, I was a contractor, and I don't know if the company has ANY record of my flying for them. Other jobs I was paid cash under the table. Another job I technically had no business relationship with the company whatsoever: I flew in trade, and the company ceased all operations after the one summer I flew there. I have no idea what that company's business address is, they don't have a valid fax #, etc.

Just asking for others' opinions here. At what point would you include Commercial level flying where you have gained experience and logged hours (even put on a resume)? And what would you leave off the official records?

Thanks!

The standard for inclusion is when a job or position appears on your resume or work history. If the position appears, it counts. It may seem silly doing a training or performance paperwork request for a part time glider towing gig, but if the position was important enough to list on your flying history it needs to go on the PRIA request forms.

PRIA only covers programs that were under Part 121 or 135. Most employers want you to fill out paperwork regarding all your former employment for the specified time period, but it's not necessary under the law, and former employers who are not 121 or 135 do not need to respond to the questionaire.

OK that makes sense. I guess I should also clarify I'm not trying to hide anything in my past, I've just worked for a lot of companies.

What would you do if a previous employer has gone out of business or doesn't exist anymore, or no longer has a mailing address?

To satisfy a prospective employer requirement for a contact, I have given home addresses where there was no business address involved. Let them try to gather the info and decide whether they need it or not. That's all you can do. I feel sorry for a couple of my former employers getting these requests because they do not get anything for fielding them.

Many of my former employers are no longer available. Because PRIA paperwork is only required for certificate holders, any former employers who aren't required to be a part of the program are irrelevant (with some exceptions).

Guidance for FAA inspectors on the administration of PRIA: http://rgl.faa.gov/Regulatory_and_Guidance_Library/rgOrders.nsf/0/1c3b938785afecc286257139006af7b5/$FILE/Order8000-88.pdf

Advisory Circular AC 120-68F:http://www.faa.gov/documentLibrary/m...%20120-68F.pdf

I wish airlines would disregard the non-Part 135 and 121 entries on our former employers list, but in my experience they want that data too. Fortunately those parties are not required to respond to such requests, only fair since they reap no benefits from sharing.

Technically the Part 91 operators are required to respond with what they have for records, as it's mandated by an act of congress. However, Part 91 operators aren't required to keep the same records, generally, that 121, 125, or 135 operators must, and can't be expected to provide the same level of information.

The Advisory Circular and other information previously given allows additional details and exemptions regarding who must respond, with what, and how.

Whether a Part 91 operator responds or not isn't predicated on any benefit the operator may receive; it's predicated on being an aviation employer "person" as required to respond to record requests under the prior records improvement act. Not all are required to do so; exceptions and special circumstances apply.

This is not quite right, and there's an important distinction to make...

A hiring airline MUST send PRIA requests to ALL employers who employed you as a pilot within the last 5 years. That includes 121, 135, 141, and 91.

All past employers are REQUIRED by law to respond with whatever relevant records they may have. The key here is that 121 (and 135 & 141) are required to retain certain records for a certain period of time, so you would expect to get records from those entities.

A part 91 operation is NOT required to keep those kinds of records. However if they DO keep relevant records then they are REQUIRED by law to provide them. Any business (aside from the most fly-by-night) will usually keep records about their employees for business management and liability purposes. But since there's no required format or structure, you never know what you're going to get from a 91 outfit. Maybe nothing, maybe relevant records, or maybe everything they have on you, including the kitchen sink. In the later case it could hurt you if they include disciplinary records which are not supposed to be included in PRIA (even something like a list of all the times you were late to work).

That is not correct, as multiple exceptions are given in the previously cited documents.

As I previously stated. There are, however, exceptions.

I am a sheriff volunteer pilot where a vast majority of my flying was derived. I was never paid. Is this something that would go on this form instead of just listing total time? Would I have to get paperwork from the sheriff's department?

My understanding (and I am not an aviation attorney):

* does the job appear on your pilot resume, or your employment history?
* was piloting a central or necessary part of the duties?
* did the job occupy any significant amount of your time?
* did the job generate a significant number of your logbook hours?
* did you get a W-2 from the employer?
* was it DOT drug and alcohol tested?

These are just a few tests that come to mind. There's no harm in erring on the side of caution and disclosure. I would think it more dangerous to fail to disclose a significant job than reporting an insignificant item to have it disregarded later.

Reference AC 120-68F, paragraph 3-4.d, page 12, previously cited (http://www.faa.gov/documentLibrary/m...0120-68F.pdf):

d.
Document “Good Faith” Attempts to Obtain Records. If a pilot/applicant’s former employer has not responded after 30 calendar-days, document your attempts to obtain the PRIA records from them and contact the PRIA program manager to determine its status. (See paragraph 3-5b below). For drug and alcohol testing records, three attempts to obtain the records within a 30-day period would be considered to be a reasonable attempt to obtain the records. If the nonresponding employer is bankrupt, out of business, or is a foreign entity, your documented attempts to contact that employer fulfill your obligation under PRIA.

The applicability of PRIA (from same source above):
1-4.
APPLICABILITY.

a.
Affected Party. PRIA specifically applies to the following:

(1)
Any U.S. air carrier operating under Title 14 of the Code of Federal Regulations (14 CFR) part 121 or 135, or any U.S. air operator under 14 CFR part 125, for the purpose of requesting records.

(2)
Any U.S. air carrier operating under part 121 or 135, any U.S. air operator operating under part 125, other person, or trustee in bankruptcy for an operator that employed the individual as the pilot of a civil or public aircraft at any time during the 5-year period before the date of the individual’s employment application for the purpose of furnishing records.

(3)
Any individual who is applying for a position as a pilot with a U.S. air carrier or operator, and has been employed as a pilot of a civil or public aircraft at any time during the 5-year period before the date of the individual’s employment application for the purpose of employment.

NOTE:
If you are a single pilot operator, you are still subject to the provisions of PRIA. Complete the PRIA forms as both the air carrier representative and the pilot (as subject of the request). In the margin of the request, enter the statement “SINGLE PILOT OPERATOR” in large letters to identify yourself as such.

Applicability to emplyoyers:

b.
Determining if PRIA Applies to You When Hiring a Pilot. Use the following checklist to determine if PRIA requires you to request records for a pilot. (Also, see the definitions in Chapter 6.) When hiring a pilot, PRIA applies and you must request records concerning a pilot/applicant if you answer “yes” to either of the two questions below.

(1)
Are you an air carrier operating under part 121 or 135, or an air operator operating under part 125?

(2)
Do you engage in air transportation as defined in 49 U.S.C. § 40102(a)(5)? You engage in air transportation if you provide:
•
Foreign air transportation (flag operation);
•
Air transportation on an interstate basis; or
•
Transportation of U.S. mail.

c.
Contract and/or Shared Pilots Concerning PRIA. Before allowing an individual to begin service as a pilot, an air carrier or air operator must request and receive PRIA-related records, regardless of whether they hire the pilot directly or by contract. In all cases, the PRIA burden is on the air carrier or air operator, not the company providing the pilot under a contract, or the individual pilot. In other words, if an air carrier or air operator is going to utilize the temporary services of a contract or shared pilot provided by a staffing-type agency or other concern, the burden remains with the utilizing air carrier or air operator to comply with the PRIA statutes.

d.
PRIA Participation by 14 CFR Part 91 Operators. If you are a part 91, § 91.147 operator (formerly a part 135, § 135.1(c) operator) you must request drug and alcohol testing records when hiring a pilot/applicant for your air tour operation. Other part 91 operators are not required to request records when hiring a pilot/applicant because they do not meet the definition of an air carrier (see the definitions in Chapter 6). However, if you operate under part 91 and you receive a request for records under the authority of PRIA, you are required to respond because you meet the definition of “person.” Thus, you must furnish any PRIA-related records you accumulated on an individual you employed as a pilot within the previous 5 years.

Exceptions:

e.
Other Exceptions From PRIA When Hiring Pilots. If you are hiring a pilot, PRIA does not apply if you (1) conduct your operations on an intrastate basis only and are not operating air tours under § 91.147, and (2) you do not transport U.S. mail even if you carry passengers and cargo, and even if you use common carriage, adhere to a schedule, and operate under an air carrier certificate. In other words, the definition of air transportation must be fulfilled before PRIA will apply to your operation.


Other exceptions include:

(1)
Flights or other operations not operating under part 121, 125, or 135 or § 91.147.

(2)
Other operators would include 14 CFR part 133 external load operators, 14 CFR part 137 agricultural operations, part 91 subparts F and K, or other unique part 91 operations. Air agencies include aviation-related companies operated in private industry but certificated by the FAA, including the following types of operations: domestic satellite repair station, parachute loft, domestic repair station, aviation maintenance technical schools, training centers, foreign repair station, and foreign satellite repair stations.

(3)
If you are a pilot that has been continuously employed by the same air carrier or air operator with no break in service since the initiation of the Pilot Records Improvement Act on February 6, 1997, you are not required to comply with the provisions of PRIA or to have a PRIA Background Report on file.

NOTE:
Even if you meet one of the above exceptions and are not required to request records when hiring pilots for your operation, if you receive a request for PRIA-related records, you are required to respond by forwarding such records that you may have accumulated concerning the pilot/applicant within the previous 5-year period.

With regard to medical reporting of PRIA, what is disclosed? Just that I have a medical and what class? Or will everything I disclosed to the doc on my 8500-8 be provided?

Anyone know how a company can get PRIA info from Comair?