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Interpreting New Guidance on EFB Use
The FAA recently published a significant revision to guidance on the use of EFBs in flight operations, which confused many operators.
The Association provided extensive comments to the FAA during development of the guidance and quickly provided a comprehensive summary of the changes to Members, available online at www.nbaa.org/ops/cns/efb
“Do I need to seek FAA approval to use an iPad in the cockpit?” This is the most common question NBAA receives from pilots and flight department managers evaluating the use of iPads or other tablet devices. With the rapid advance of electronic flight bag (EFB) technology, the Federal Aviation Administration (FAA) has been working to create guidance that keeps pace with how pilots are using the devices. In 2011, the FAA began the process of revising Advisory Circular (AC) 120-76 on E FB certification and operational use.
Existing guidance from the FAA in AC 91-78 explains that operators conducting flights under Part 91 of the Federal Aviation Regulations (FARs) are allowed to use devices such as the iPad in place of paper aeronautical charts. However, during the revision of AC 120-76, the FAA created specific EFB testing and documentation requirements for operators flying large (over 12,500 lbs) or multi-engine turbine-powered aircraft under Part 91F.
While the published AC 120-76B creates guidance specific to 91F operators, FAA authorization is not required for EFB use as long as the device does not replace any system or equipment required by regulation. However, the AC does explain that 91F operators should document their compliance with a number of items as they transition to EFB use.
For example, 91F operators are allowed to use an EFB in lieu of paper reference material without specific FAA approval, but the AC advises documenting how operators evaluated the EFB and determined its suitability as a paper replacement. The AC also suggests a validation period during the paperless transition and a backup source of aeronautical information, which can be paper-based or a secondary EFB.
There are also various testing requirements that the AC suggests 91F operators comply with and document. Testing the EFB to ensure that it does not interfere with other electronic systems on board the aircraft is important. The AC provides a process operators can use to complete this testing. With the increased focus on battery safety, the AC also advises that operators document a maintenance plan for lithium-ion batteries.
Clarifying the Details
One area of significant confusion surrounds the requirements to conduct rapid decompression testing on EFBs that will be used in pressurized aircraft. The AC makes clear that decompression testing does not need to be completed on every single EFB, and obtaining documentation that testing was successfully completed on a representative device is adequate. Many of the vendors that provide software applications for devices such as the iPad are able to provide evidence of successful decompression testing.
Although AC 120-76B does not specifically apply to Part 91 operations (other than 91F and 91K), the guidance should still be consulted as a reference. For Part 135 and other certificated operators, formal approval is required for EFB use through the issuance of OpSpec A061.
With the publication of AC 120-76B, all Part 91 operators are still allowed to use EFBs without formal FAA approval, but 91F operators are advised to document compliance with a significant number of items. Even with the expanded FAA guidance, the pilot in command for Part 91 flights is still ultimately responsible for ensuring the safe and reliable use of an EFB.
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