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2.8.3.1 Company records are events or actions memorialized by an air carrier or operator to document compliance with a statute or regulation, or maintained through a company’s own initiative. These records typically are comprised of documented training and qualification events, performance, and employment-related activities during the period that an individual is employed by a company as a pilot.
2.8.3.2 PRD records are those obtained through the PRD or otherwise as required by part 111. These records are used to assist a reviewing entity in making a hiring determination. PRD records are not forwarded to another reviewing entity through a future request made in accordance with part 111.
2.8.3.3 PRD records will be archived and maintained completely separate from the reviewing entities “company” records. PRD records should never be actively used again, other than for inspection and review by that company’s FAA Principal Operations Inspector (POI) in order to verify compliance with part 111.
2.8.3.4 A PAR is never to be considered as a reviewing entity’s own “company” records. Companies must only enter records they generate about the pilot into the PRD.
2.8.4 Method of Entry for Pilot Records.35 Initially, the FAA will offer two acceptable methods for reporting entities to report data elements to the PRD. Each reporting entity could opt to use either of the methods described below. A reporting entity may also use both methods but must never report the same record using both methods as this will result in duplicative records in the PRD.
Note: The two reporting options described below are expected to be deployed on different development schedules. Option 2 is expected to be available one year after publication of part 111 which coincides with the initial reporting requirements of part 111 subpart C. Option 1 is expected to be available between one and two years after publication of the part 111.
2.8.4.1 Reporting Method Option 1: Data Transfer Using an Automated Utility.
2.8.4.1.1 The first option is transmitting data electronically using an automated utility.
In order to use this method, the employer would encode the relevant data using an automated utility using Extensible Markup Language (XML) or similar process, so it can be read by both the user and the PRD. The data is transmitted through the PRD application, and the PRD application would be able to extract the relevant information for each pilot and input the information into the appropriate fields in the PRD. Use of an automated utility
35 The PRD complies with federal information security requirements and the FAA has published a PIA for the system, available at https://www.transportation.gov/privacy.
2-45 would minimize the amount of time and effort necessary for an employer to transmit data to the PRD.
2.8.4.1.2 The amount of time an air carrier or other operator employing pilots will spend transmitting data to the PRD using such an automated utility will depend on the user’s internet connection, and volume of data being sent to the PRD. All data is transferred in XML via the automated utility by automatically populating the specified data fields. This requires that the automated utility’s data fields correspond correctly with the PRD’s data fields.
Refer to the Resources section at prd.faa.gov for instructions on setting up the automated utility.
2.8.4.2 Reporting Method Option 2: Manual Data Entry. The second method for air carriers and others employing pilots to transmit data to the PRD is through direct manual data entry, using the same pre-established data field forms for each record type. An air carrier or other operator employing pilots would use manual data entry to report the requisite information from its existing records, regardless of the format in which the records have been stored. The FAA expects that this method would only be used by those operators without the technical capability to use an automated utility using XML. Refer to the Resources section at prd.faa.gov for manual data entry instructions.36
2.8.5 Record Ownership. When a reporting entity enters a record into the PRD, the reporting entity becomes the owner of that record. The record owner is the only entity that can edit the record after it has been created. The PRD allows the transfer of record ownership from one entity to another upon acceptance of responsibility for the record content. For example, this might occur due to a merger of two airlines. Or, in the event of a business closure, the reporting entity might elect to transfer ownership of the records to a third party. Changes of record ownership are a special function. Contact the PRD administrator for assistance.
2.9 Using a Proxy to Meet the Requirements of Part 111. An air carrier or operator may choose to utilize a proxy to meet the requirements of part 111. However, an air carrier or operator maintains the responsibility to ensure compliance with part 111. Certain documentation is necessary from the FAA for a proxy to gain access to the PRD. Refer to the Resources section at prd.faa.gov for further proxy instructions.
2.10 Transitioning From PRIA to the PRD.
2.10.1 Overview. Although the PRD will replace PRIA, for 3 years and 90 days after part 111 publication PRIA is still in effect. However, part 111 has requirements which overlap with PRIA and can often be met concurrently. The overlap exists to ensure that pilot records remain available to hiring employers before they can be entered into the PRD.
During the transition period, hiring employers will need to check both PRIA and the PRD to make sure they have reviewed all of the records. This section of the AC will describe
36 The manual data entry method is expected to be available one year after publication of part 111, and concurrently the Resource guide will also become available.
2-46 how those affected by PRIA as well as part 111 can navigate this transition period. The easiest way for an operator to understand the transition is to break it into three main parts:
continued compliance with PRIA, historical record reporting, and new record reporting.
2.10.2 Continued Compliance with PRIA. Until the expiration of 3 years and 90 days after publication of part 111, certain hiring operators must continue to make PRIA requests for pilot records as part of the hiring process. The effected operators have not changed in this respect. If an effected operator is required to request records under PRIA, that operator must continue to comply with PRIA for 3 years and 90 days after part 111 is published.
The way the operator requests and views those records, however, might change. If the operator receives a PRIA records request, the operator must respond under PRIA until PRIA is sunset. Part 111 uses a phased in compliance schedule to allow plenty of time for employers and pilots to become accustomed to using the PRD and for the system to be loaded with the appropriate records.
2.10.2.1 1–179 Days After Publication. During this period, no changes concerning how a hiring employer will request records under PRIA or how a previous employer will provide those records will take effect. Prior to 90 days after publication of the final rule, all operators, entities, and bankruptcy trustees (if applicable) subject to part 111 must create an RP account in the PRD in accordance with § 111.15. This allows plenty of time for industry and the FAA to ensure everyone is ready for the next big milestone which occurs at 180 days after publication.
2.10.2.2 180 Days After Publication. Any operator that is required under PRIA to review FAA records will now review those records via the PRD in accordance with § 111.100(b). Instead of asking the pilot to complete FAA Form 8060-10 and sending that form to the FAA, you will now use the PRD. The process is detailed in paragraph 2.6.2.2, but the general process involves two basic steps.
First, the pilot logs into the PRD and grants consent to the hiring operator to see the FAA records. Second, the hiring operator logs into the PRD and views the FAA records.
2.10.2.3 One Year After Publication. One year after publication of part 111 operators defined as “reviewing entities” must begin to review any pilot records in the PRD in accordance with § 111.100(b). At the same time, reporting entities must start entering new pilot records as well as historical records into the PRD in accordance with § 111.200. If PRIA requires an operator to review records, the operator will review the FAA records and any industry records available in the PRD. If additional records are available and not yet reported to the PRD, the operator will need to request those previous employer records by sending FAA Form 8060-11 or making the request via the PRD system itself. The PRD system offers an easy function to request records about a pilot if the previous employer has not yet entered them into the PRD. If an operator is a previous employer and receives a request for records, the operator can either provide those records via the mail, email, etc. or enter those records into the PRD.
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2.10.2.4 Two Years After Publication. Operators will notice many more pilot records are available in the PRD now because reporting entities described in part 111 must complete entering pilot records from January 1, 2015 to the present.
Reporting entities are also continuing to report new records contemporaneously. Operators required by PRIA to review records will still check records in the PRD and request any additional records which are still outstanding. Those responding to requests can either enter the records at that time or return the records to the requester as they have done for years under PRIA. It does make sense for the previous employer to just enter the records when asked because that means any future requests would be pre-resolved.
2.10.2.5 Three Years and 90 Days After Publication. PRIA ceases to be effective.
Reviewing entities must only comply with the PRD to review pilot records.
They may also still need to request additional records via the PRD system as there are still some situations where additional records may be available.
However, the option to send FAA Form 8060-11 will end and pilot records must be entered into the PRD in response to a records request. Under part 111, employers now enter records into the PRD within 30 days of creation and the records wait until a reviewing entity needs them, subject to certain exceptions.
2.10.3 Historical Record Reporting. Part 111 allows two years for each reporting entity to enter their historical records dating from January 1, 2015. During the transition from PRIA to the PRD, only some pilot records will be in the PRD. As a result, beginning one year after publication, operators must continue to comply with PRIA as well as review all records in the PRD.
2.10.3.1 Historical Records Dated On or After January 1, 2015. Certain reporting entities have been required by the PRD Act to maintain their historical pilot records since 2010 for reporting into the PRD. Air carriers are required to enter pilot records from 2005. The FAA recognizes that this is a significant effort and it also realizes that more recent records tend to have more value to a reviewing entity. With this in mind, § 111.255(d) requires that those required to report historical records must start entering these more recent records one year after publication of part 111 and complete entering these more recent records by two years after publication.
2.10.3.2 Historical Records Dated Before January 1, 2015. Also in accordance with § 111.255, these older historical records are required to be entered into the PRD beginning one year after publication and finishing by 3 years and 90 days after publication of part 111.
2.10.4 New Record Reporting. Beginning one year after publication of part 111, reporting entities must begin entering any records generated after that date into the PRD within 30 days in accordance with § 111.205. Certain exceptions exist for PAC operators, as described in paragraph 2.8.1.6.
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2.11 FAA Inspectors’ Access to PRD Records.
2.11.1 Employer. An air carrier or air operator cannot deny an FAA inspector access to PRD-related records for audit or surveillance.
2.11.2 Authority. Title 49 U.S.C. § 41709 provides authority for the FAA inspector assigned to that company to see those records. As a result, the inspector must always have unrestricted access to a company’s PRD-related records at any time during the course of that inspector’s normal surveillance or inspection duties.
2.11.3 Record Denial. Section 119.59(e) states that the failure by any certificate holder to make available to the Administrator upon request, the certificate, OpSpecs, or any required record, document, or report is grounds for suspension of all or any part of the certificate holder’s certificate and OpSpecs, to include PRD records.
2.11.4 Privacy. Each FAA inspector, however, having viewed such records, is also subject to the privacy protection requirements as outlined in 49 U.S.C. § 44703(i)(9). The FAA inspector must make every effort to protect the privacy of the pilot and the confidentiality of the PRD-related records of that pilot.
3-1 CHAPTER 3. PILOT RECORDS IMPROVEMENT ACT OF 1996 Note: The information provided in Chapter 3 is specific to PRIA and may not be the same as described in Chapter 2 for the PRD.
3.1 Purpose of This Chapter. This chapter provides information to facilitate compliance with the provisions of Title 49 of the United States Code (49 U.S.C.) § 44703(h), the Pilot Records Improvement Act of 1996 (PRIA). PRIA requires air carriers and other operators to gather and share information relating to a pilot-applicant’s qualification and safety background. An air carrier or air operator must request those records so it can make an informed decision before an individual is placed into service as a pilot. PRIA applies to any hiring air carrier or air operator, whether they hire pilots directly or by contract. Part 111 specifies that PRIA remains in effect for 3 years and 90 days after part 111 is published.
3.2 How to Use This Chapter. The FAA wrote this chapter for three audiences: the pilot-applicant, hiring employers that request PRIA records, and former employers that respond to PRIA records requests. You do not have to read the entire document to find the information you need. Paragraph 3.4 describes the applicability of PRIA. Pilots applying for a job with an air carrier or air operator that will have to request PRIA records should read paragraph 3.9. Hiring employers should read paragraphs 3.10 and
3.12; and those employers responding to PRIA records requests should read paragraph 3.11. Chapter 4 is for all affected parties, as it contains some PRIA specific definitions, resources, and PRIA contact information. See paragraph 2.10 for information about how the PRD can be used to comply with PRIA during the transition in which both PRIA and PRD are in effect.
3.3 PRIA Background. On October 9, 1996, the President approved the Federal Aviation Reauthorization Act of 1996 (the Act). The Act amended 49 U.S.C. to reauthorize programs of the FAA and to effect certain changes, including pilot records. The law is commonly referred to as PRIA and is contained in Section 502 of Public Law (PL) 104-264, Federal Aviation Reauthorization Act of 1996. PRIA was enacted primarily as a result of certain accidents attributable to pilot error. In some of those cases, the subsequent employer found that the pilots had previous histories of poor performance, but the background of these pilots had not been checked. PRIA was amended to make clarifications and relieve air carriers of unnecessary burdens. These amendments to PRIA are in 49 U.S.C. § 44703(h), (i), and (j).
3.3.1 PRIA Review. A pilot may begin training with the new employer before the PRIA check has been completed. However, all PRIA checks must be completed, evaluated, and approved before the individual can begin service as a pilot for that hiring employer, in accordance with 49 U.S.C. § 44703(h)(1).
3.3.2 Pilot Records Database (PRD). The Airline Safety and Federal Aviation Administration Extension Act of 2010 (the Act) amended PRIA and required the FAA to create the PRD.
The PRD is required to contain pilot records dating from August 1, 2005 for FAA certification events, enforcement records, pilot employment history, training data, and
3-2 drug and alcohol testing records. Once the transition period is complete, the PRD will replace PRIA. Until full implementation of the PRD, PRIA remains in effect. Therefore, air carriers and other operators who employ pilots must continue to provide pilot records to an air carrier or air operator seeking information on an individual pilot in accordance with PRIA. PRIA requires air carriers to evaluate all available pilot records prior to making a hiring decision. See paragraph 2.10 for information about how the PRD can be used to comply with portions of PRIA.
3.4 Applicability.
3.4.1 Affected Parties. PRIA specifically applies to the following:
3.4.1.1 Any U.S. air carrier operating under 14 CFR part 121 or 135, or any U.S. air operator under 14 CFR part 125 or 135 for the purpose of requesting records.
3.4.1.2 Any U.S. air carrier operating under part 121 or 135, any U.S. air operator operating under part 125 or 135, 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.
3.4.1.3 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.
3.4.1.4 Single pilot operators are 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.
3.4.1.5 Operators not required to request records when hiring pilots should still respond to requests for PRIA-related records by forwarding such records that the operator may have accumulated concerning the pilot-applicant within the previous 5-year period or a statement to the effect that there are no records available to be forwarded.
3.4.2 Determining Whether PRIA Applies to You When Hiring a Pilot. Use the following checklist to determine whether PRIA requires you to request records for a pilot. You must request records concerning a pilot-applicant if you answer “yes” to either of the two questions below.
3.4.2.1 Are you an air carrier or operator conducting operations in accordance with 14 CFR part 91 subpart K (part 91K), 121, 125, or 135?
3.4.2.2 Do you engage in air transportation, as defined in 49 U.S.C. § 40102(a)(5)?
You engage in air transportation if you provide:
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• Foreign air transportation (flag operation),
• Air transportation on an interstate basis, or
• Transportation of U.S. mail.
Note: Notwithstanding the above comments, all operators should consider voluntarily requesting PRIA records and any other records that may be available.
3.4.3 Contract or Shared Pilots Concerning PRIA. Before allowing an individual to begin service as a pilot, PRIA requires an air carrier or air operator to 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. Therefore, 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.
3.4.4 PRIA Participation by Part 91 Operators. If you operate under part 91 and you receive a request for a pilot’s records under the authority of PRIA, you should respond. Therefore, you should furnish any PRIA-related records you accumulated on an individual you employed as a pilot within the previous 5 years, or if there are no records to forward, simply state that there are none and return the request. This will enable the requestor to close out and complete their PRIA checks and then proceed with their hiring process.
3.4.4.1 If you operate as a fractional ownership under part 91K you are required to request and evaluate records in accordance with § 91.1051. If you are an operator as defined under § 91.147, you must request drug and alcohol testing records when hiring a pilot-applicant for your air tour operation in accordance with 49 CFR part 40.
3.4.4.2 If you are a pilot who has been continuously employed by the same air carrier or air operator with no break in service since the initiation of PRIA on February 6, 1997, your employer is not required to have a PRIA Background Report on file.
3.5 Company Records vs. PRIA Records. Pilot employers typically maintain records that exceed the scope of records to which PRIA applies. Such records are referred to as “company records,” whereas the records maintained and provided by operators in accordance with PRIA are referred to as “PRIA records.” The difference between the record types can easily create confusion among those involved during review.
3.5.1 Company records are events or actions memorialized by an air carrier or operator to document compliance with a statute or regulation or those maintained through a company’s own initiative. These records typically consist of documented training and qualification events, performance, and employment-related activities during the period
3-4 that an individual is employed by a company as a pilot. Many company records exceed the scope of PRIA.
3.5.2 PRIA records are a collection of company records memorialized by a current or former employer during the previous 5 years from the date of the request that meet the policy outlined in this AC and the requirements of 49 U.S.C. § 44703(h). These records are used to assist an air carrier or operator in making a hiring determination. PRIA records are not forwarded from a receiving air carrier to another requesting air carrier through a future PRIA records request.
3.5.3 When a pilot is seeking employment with an employer that is required to review records in accordance with PRIA, the employer will request records from the pilot’s current and/or previous employers. The previous employers will then assemble copies of the appropriate records for the past 5 years.
3.5.4 Once the company records have been assembled by the current and/or former employers of the pilot applicant, at that point, that subset of company records become PRIA records.
3.5.5 Those PRIA records will be archived and maintained completely separate from the hiring air carrier or operator’s company records. PRIA records received through a PRIA records request should never be actively used again, other than for inspection and review by that company’s Principal Operations Inspector (POI).
3.5.6 PRIA records received as a result of a PRIA records request should never be included in an employer’s own company records when that employer receives a subsequent PRIA records request. The company holding the PRIA records must respond to a PRIA records request only from their company records and never forward another company’s PRIA records as part of the records sharing process.
3.6 The Request Process. The following is a brief overview of the entire PRIA process.
Subsequent paragraphs detail the roles and responsibilities for the pilot-applicant, the hiring employer, and the current or former employer. See paragraph 2.10 for information about how the PRD can be used to comply with portions of PRIA.
3.6.1 Initiation. The hiring employer initiates the process.
3.6.2 PRIA Records Request. Both the pilot-applicant and the hiring employer complete the PRIA records request forms.
3.6.3 Employer. The hiring employer sends the request forms to the:
• FAA,
• National Driver Register (NDR), and
• Current and previous employers.
3.6.4 Response. Respondents answer the PRIA records requests.
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3.6.5 Review. All pilots/applicants may review records submitted about them to the FAA, NDR, and current and previous employers.
3.6.6 Evaluation. The hiring employer reviews and evaluates the results.
3.6.7 Records Maintenance. The hiring employer maintains all PRIA-related records.
3.7 Designated Agent (DA). A requesting air carrier or air operator has the option of employing a “third-party processor,” commonly known as a DA or proxy, to complete all of their PRIA checks.
3.8 Best Practices. The FAA expects that pilots, hiring air carriers, and air operators, as well as past employers, will use these best practices to ensure they are operating to the highest level of safety.
3.8.1 PRIA Records Request. The FAA expects all hiring air carriers and air operators to request all FAA records of proficiency and competency as well as airmen certification practical test results. These records can be requested by obtaining a release from the applicant (see Appendix G).
3.8.2 Release Form. Hiring air carriers and air operators should not consider an applicant for employment if that applicant will not sign the release for the additional FAA records.
3.8.3 Disclosure. The FAA expects a pilot/applicant to disclose all pilot testing failures to any potential employer to which PRIA applies.
3.9 Information for the Pilot-Applicant.
3.9.1 Pilot-Applicant’s Tasks During PRIA Records Request Process. If you are an individual who is applying for a job as a pilot, your hiring employer will initiate the PRIA records request process. Per 49 U.S.C. § 44703(h)(5) and (6), the hiring employer must first notify you in writing that it will request records about you and obtain your written consent by signature.
3.9.1.1 Complete PRIA Records Request Forms.
3.9.1.1.1 The hiring employer or a DA will provide several forms to request PRIA-related records from the previous 5 years only. You will complete and sign these forms to grant your consent for the FAA, your previous employer(s), and the NDR to release your records.
3.9.1.1.2 The Aviation Data Systems Branch will provide information concerning your current airman medical certificate. It will also give information on your current airman certificates indicating level, category, class, and associated type ratings, including any limitations to those certificates and ratings. From the previous 5-year period, the FAA will also summarize any closed legal enforcement actions against you that resulted in findings of violations that were not subsequently overturned. However, the FAA will report any formal
3-6 closed certificate actions on file, such as suspensions, civil penalties, or revocations indefinitely.
3.9.1.1.3 The hiring employer will ask your previous employer(s) to provide records pertaining to you, except for those related to flight time, duty time, or rest time. A previous employer will provide records on your performance as a pilot concerning your training, qualifications, proficiency, and professional competence, including any comments or evaluations by check airmen; any disciplinary actions that the previous employer did not overturn; and any release from employment or resignation, termination, or disqualification from employment. Additionally, under PRIA, your former Department of Transportation (DOT)-regulated employer(s) will provide records of drug and alcohol tests performed under 49 CFR part 40, even if the employers were not aviation entities.
3.9.1.1.4 If this is your first job as a pilot, but you were previously subject to DOT-regulated drug and alcohol testing, your hiring employer must request your drug and alcohol test results from your previous employer(s) in accordance with 49 CFR part 40.
3.9.1.1.5 The NDR will furnish your applicable motor vehicle driving records.
3.9.1.2 Request Copies of Records.
3.9.1.2.1 Records from the FAA. The Aviation Data Systems Branch will automatically send you an identical copy of the PRIA verification letter that it furnishes to the hiring employer. As a security measure, the Aviation Data Systems Branch will send this report to your home address, as shown in the records maintained by the Airmen Certification Branch. Ensure that the Airmen Certification Branch has your current home address by updating it online at https://registry.faa.gov or by calling toll free at 866-878-2498. In addition, the hiring employer may, at its discretion, request a record of your Notices of Disapproval from the FAA.
3.9.1.2.2 Records from Previous Employers and the NDR. If desired, you can request copies of records that your previous employer(s) maintained, including those from the NDR. If the hiring employer uses the recommended FAA forms to request records, then FAA Form 8060-11A, Airman Notice and Right to Receive Copy – Air Carrier and Other Records (PRIA), is the proper form to use when requesting copies of your pilot and drug and alcohol testing records from your previous employer(s). If you requested a copy of your current NDR records, the hiring employer should furnish them to you after receiving them from the NDR.
Note: PRIA permits respondents to charge a reasonable fee in a “statement of payment” to recoup the cost of furnishing records to you.
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3.9.1.3 Review Records and Submit Corrections. You may review the records received and, if necessary, submit a written statement to correct any inaccuracy or omission in your records. The hiring employer should include your statement in the PRIA-related records file that it compiles on you to represent your viewpoint concerning those records or entries. It is recommended that you ensure that the hiring employer has a copy of any such corrections.
3.9.1.4 Sign Release of Liability. Hiring employers or former employers may require you to sign a release from liability for records other than the drug and alcohol testing records, in accordance with 49 U.S.C. § 44703(h)(2)(B). The release from liability can state that you will not make any claim against them for requesting or furnishing PRIA records, but would not apply if an employer furnishes information known to be false or maintained it in violation of a criminal statute. Under 49 CFR part 40, § 40.27, an employer must not ask an employee to sign a consent, release, waiver of liability, or indemnification agreement with respect to any part of the drug or alcohol testing process.
3.9.1.5 Your Right to Receive Copies of Records. In accordance with 49 U.S.C.
§ 44703(h)(6), the FAA and your former employer(s) are required to give you written notice of the request and notice of your right to receive copies of the records within 20 calendar-days of receiving a PRIA records request.
3.9.1.6 PRIA Records Request. If you have requested a copy of your records, these respondents (FAA or former employer) can fulfill this requirement by providing the records to you within 30 calendar-days in accordance with 49 U.S.C. § 44703(h)(10).
3.9.2 A Pilot’s Expectations and Protections under PRIA. All professional pilots whom a hiring employer is considering for employment have certain protections concerning the request, transfer, receipt, evaluation, and maintenance of their records.
3.9.2.1 PRIA Statutory Provisions. In accordance with PRIA, the hiring employer must provide you with the following:
1. Written notification that the hiring employer will make a request for your PRIA-related records.
2. A consent form to sign for the release of those records.
3. An opportunity to request a copy of those records if so desired.
Note: Use of FAA forms provided to employers fulfills the three requirements stated above.
4. An opportunity to submit a written comment or memorandum to a former or potential employer when you believe there are inaccuracies in your PRIA-related records. This written comment should be submitted to the previous employer for entry into your records maintained by the previous