Sofema Aviation Services (SAS) www.sassofia.com considers the Mandatory and Voluntary reporting requirements specifically related to GACAR Part 145 and GACAR Part 43 organisations
Introduction
In both GACAR Part 145 and GACAR Part 43, mandatory reporting focuses on identifying and addressing safety-critical defects, maintenance failures, and operational interruptions. These reporting criteria are vital for ensuring the continued airworthiness and safe operation of aircraft by identifying potential hazards early and implementing corrective actions.
- Organizations and individuals involved in aircraft repair and maintenance are required to report major defects, service difficulties, and improper maintenance practices to mitigate safety risks in aviation operations.
Below are examples of criteria applicable to mandatory reporting under these two GACAR parts:
GACAR Part 145 (Aircraft Repair Stations)
Organizations operating under GACAR Part 145 are required to report various maintenance-related issues that could affect the safety of aircraft and their components. The criteria for mandatory reporting include:
Service Difficulty Reporting (SDR)
- Service Difficulties: Part 145 organizations must report any significant service difficulties they encounter during maintenance operations. This includes mechanical failures, malfunctions, or defects in aircraft, engines, systems, or components that could compromise the safe operation of the aircraft.
- Example: A major failure in a flight control system that was discovered during maintenance
- Component Failures: Any significant defect or malfunction in a critical aircraft component (such as flight control surfaces, landing gear, or fuel systems) that could impact flight safety must be reported.
Defect Reporting
Part 145 organizations must report major defects in aircraft and their components that could affect safety, such as:
- Major Structural Damage: Damage such as cracks, delamination, or deformation found during inspections that could compromise the structural integrity of the aircraft.
- Serious Leakage or Contamination: Any serious leakage of fluids (e.g., hydraulic, fuel, oil) that presents a fire hazard or potential contamination of critical systems.
- Incorrect Assembly: Discovery of improperly installed or assembled aircraft components that could lead to safety hazards.
Mechanical Interruptions
- Significant Mechanical Interruptions: Part 145 organizations must report mechanical interruptions causing delays or operational issues during aircraft operations. These interruptions are often linked to maintenance or component failures.
Investigation of Defects
- Mandatory Investigation of Defects: GACAR Part 145 requires organizations to investigate major defects and report their findings to GACA within specified timeframes (e.g., 30 days for most major defects or up to 90 days for complex investigations).
- These reports must include detailed information on the cause of the defect and the corrective actions taken to prevent recurrence.
Part 43 (General Maintenance)
GACAR Part 43 governs maintenance, preventive maintenance, and alterations, and it imposes mandatory reporting requirements for any maintenance activities that result in safety-related issues or defects. The key reporting criteria under Part 43 are:
Major Repairs and Alterations
- Major Repair or Alteration: Any major repairs or alterations to an aircraft or its components that affect its safe operation must be reported. This includes significant structural repairs or changes to the aircraft’s design or systems.
Defective Maintenance or Inspection
- Incorrect or Defective Maintenance: Any maintenance action that was carried out incorrectly or led to a defect in the aircraft must be reported. This includes situations where inspections reveal maintenance actions that were improperly performed or that introduced new safety issues.
Failure of Safety-Critical Systems
- Failure of Aircraft Systems: Any failure or malfunction of an aircraft system or component that affects safety must be reported. This applies to systems like propulsion, flight control, navigation, and other critical components.
Use of Bogus or Unapproved Parts
- Bogus or Unapproved Parts: GACAR Part 43 requires the reporting of any discovery of bogus or unapproved parts used during maintenance activities. These parts pose significant safety risks if installed on aircraft.
Non-compliance with Maintenance Standards
- Non-compliance with Maintenance Procedures: Any failure to follow prescribed maintenance procedures or use of incorrect maintenance data must be reported, especially if it results in unsafe conditions.
- Incident Reporting:
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- Incidents related to the technical conditions, maintenance, and repair of the aircraft must be reported to the President. These incidents are listed in Appendix C of the document and must be investigated and reported
Confidentiality:
- Organizations must ensure that voluntary safety reports are confidential and the data from these reports is used exclusively to improve safety
GACAR Part 42 (Continued Airworthiness Management)
Mandatory Reporting:
- Operators and organizations must report major defects in components or systems that affect the safety of aircraft operations.
- Notifications must include details such as the defect, corrective actions, and other relevant information.
Voluntary Reporting:
The voluntary reporting system under GACAR Part 4 plays a critical role in enhancing aviation safety by allowing organizations and individuals to report safety concerns and hazards that might not be captured through the mandatory reporting process.
In addition to mandatory reporting, Part 145 and Part 43 organizations must establish a voluntary reporting system for capturing safety concerns not covered under mandatory reports.
The voluntary system works in tandem with the mandatory reporting system to create a comprehensive safety net. While mandatory reporting ensures that significant incidents and defects are addressed, the voluntary system captures the less obvious but equally important safety data. Together, they help form a holistic safety framework that is central to GACAR’s regulatory approach.
Requirement to Create a System
Each GACAR Part 145 and Part 43 organization must establish a voluntary reporting system to capture safety occurrences that may not be covered by mandatory reporting.
- Inclusiveness: This system must be accessible to all individuals within the organization, allowing any employee to report safety concerns or hazards voluntarily without fear of punishment.
- This can include reporting unsafe conditions, practices, or latent hazards that might not yet have caused an incident.
Purpose and Scope of the Voluntary Reporting System
The voluntary reporting system exists to supplement the mandatory reporting system by capturing safety-related events or conditions that might not meet the threshold of mandatory reporting but could still pose significant risks if left unaddressed.
This could include latent safety hazards, near misses, procedural deviations, or any other safety concerns.
- The voluntary system is designed to capture more subtle, potentially unsafe conditions that have not yet caused harm but could lead to safety issues in the future if not corrected.
- The voluntary reporting system encourages a proactive approach to safety, prompting individuals at all levels (from front-line workers to management) to recognize and report hazards before they escalate into more serious issues.
Protection and Confidentiality
A key aspect of the voluntary reporting system is the confidentiality and protection it provides to reporters. This system is designed to ensure that individuals feel safe in reporting safety concerns without fear of reprisal.
Specific provisions include:
- Confidential Reporting: Reports can be submitted anonymously or confidentially, and organizations are required to safeguard the identity of the reporter. This can be done through internal reporting systems or directly to GACA (General Authority of Civil Aviation) via web-based or hard-copy submission.
- Immunity from Punitive Action: GACAR Part 4 provides immunity to individuals who report safety issues through the voluntary reporting system.
- The purpose is to foster a culture of safety rather than one of blame. GACAR Part 13 outlines the immunity provisions, ensuring that those who report voluntarily will not face punitive action as long as their reports are made in good faith and without gross negligence or willful misconduct
- Organizational Support: Each organization must establish a voluntary reporting system that is accessible to all employees, ensuring that everyone has the opportunity to contribute to the organization’s safety data.
- Organizations must designate staff responsible for collecting, evaluating, and analyzing voluntary reports.
Integration with the Safety Management System (SMS)
The voluntary reporting system is an essential component of an organization’s Safety Management System (SMS). The data collected through voluntary reports helps organizations identify emerging safety trends and potential hazards before they result in accidents or serious incidents.
- Hazard Identification: Reports gathered through this system provide invaluable insights into latent risks and operational issues that might not be evident through routine audits or inspections. These hazards can then be addressed through changes in procedures, additional training, or technical interventions.
- Trend Analysis: By systematically reviewing voluntary reports, organizations can detect recurring issues or patterns, allowing for more effective risk mitigation.
- This data also contributes to building the broader safety database that supports the entire civil aviation system of the Kingdom of Saudi Arabia.
Procedural and Legal Framework
The voluntary reporting system is regulated under specific provisions to ensure standardization and efficiency.
Some of the key procedural requirements include:
- Reporting Mechanism: Organizations must provide an easy-to-use channel for voluntary reports. The process should be well-documented in the organization’s manuals, including details on how the information will be handled, analyzed, and shared internally and with GACA.
- Handling of Reports: Organizations are required to independently manage the collection, evaluation, and analysis of voluntary reports. This ensures that there is no conflict of interest and the reporting process is handled in a neutral manner.
- Use of Data: Voluntary reports are not used for regulatory enforcement or punitive actions against individuals. Instead, the data collected is used to improve overall safety through analysis, procedural changes, and training. GACAR mandates that this data be shared with the President and the Aviation Investigation Bureau (AIB), and it also feeds into the State Safety Program (SSP)
Next Steps
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Defect Reporting, Framework, Protection, Confidentiality, Unapproved Parts, Safety-Critical Systems, Major Repairs, General Maintenance, Mechanical Interruptions, Service Difficulty Reporting, reporting requirements, aviation, Aircraft Repair Stations, Voluntary Reporting System, SAS blogs, Continued Airworthiness Management, GACA, Kingdom of Saudi Arabia, GACAR Part 43, GACAR Part 145, Aviation Safety Management System, State Safety Program SSP
