Voluntary Reporting and a Suspected Unapproved Part
While doing a scheduled inspection on an H125, you find a main rotor pitch link bearing that does not match the illustrated parts catalogue. The part number is close but has an extra suffix, and the accompanying 8130-3-style release document (in this jurisdiction, a CAR 84 authorised release certificate) shows a different part number from the one fitted. The aircraft has flown 240 hours since the part was installed two annual inspections ago. You raise it with the DOM, who says the part was 'probably a superseded variant' and asks you not to make a fuss because the operator is a key customer and a report would trigger a full fleet inspection. You are aware that the regulator operates a voluntary reporting scheme for maintenance errors and hazards, and that mandatory occurrence reporting also exists under the Civil Aviation Act 2017. You have not yet signed anything.
1. Distinguish between the mandatory and voluntary reporting routes available, and identify which applies to this situation.
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Mandatory occurrence reporting under the Act and CAR 84 captures specified reportable occurrences - serious incidents, airworthiness deficiencies with a defined safety effect, and unapproved parts fitted to a type-certificated product are typically within scope. Voluntary reporting is a separate, non-punitive channel for hazards, errors and near misses that may not meet the mandatory threshold but carry safety learning value. Here, a suspect unapproved part fitted to a critical rotor component is likely a mandatory reportable occurrence as well as a voluntary-report candidate. The two are not alternatives: you should file the mandatory report because the threshold is met, and may additionally file a voluntary report describing how the discrepancy escaped detection for 240 hours. The DOM's request not to report does not displace the statutory duty.
2. What are the consequences for you personally if you comply with the DOM's request and certify the aircraft?
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Certifying an aircraft with a known suspect unapproved part is a false certification. It exposes you to licence action (suspension or revocation), possible prosecution under the Act, and personal liability if the part fails. It also defeats the purpose of the release certificate system. The DOM's commercial argument is not a defence: the regulations place the certification duty on the licence holder, and 'the customer is important' is not an approved deviation. You should refuse to certify until the part is positively identified as approved or replaced.
3. Outline the steps you would take, in order, from discovery to resolution.
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First, quarantine and document: photograph the part, record the part number, the release document number and the discrepancy, and do not return the part to service. Second, notify the DOM in writing that you are raising a mandatory occurrence report and that you will not certify until resolved. Third, file the report with the regulator through the prescribed channel, keeping a copy. Fourth, contact the manufacturer or approved distributor to establish whether the suffix denotes an approved variant; if it does, obtain written confirmation and record it. Fifth, if it is not approved, replace the bearing with an approved part and inspect the fleet for the same discrepancy. Sixth, file a voluntary report on the process failure that allowed the wrong release document to be accepted. Finally, ensure the organisation's incoming-parts inspection procedure is reviewed.