Egyptian Civil Aviation Supervisory Authority Egyptian Advisory Circular Number 00-1

VOLUNTARY DISCLOSURE REPORTING PROGRAM

EAC001.1 Purpose
This Egyptian Advisory Circular (EAC) provides information and guidance material for
establishing a Voluntary Disclosure Reporting Program (VDRP). Any certificate holder
certified under the Egyptian Civil Aviation Regulations (ECARs) may implement this
program in accordance with Partnership 2000 guidance (Egypt Information Bulletin EIB-
1/2000). The procedures and practices outlined herein may be used when freely disclosing
obvious violations of the ECARs to the Egyptian Civil Aviation Authority (ECASA).
These procedures and practices can be applied to all aspects of civil aviation including
maintenance departments, flight operations departments, repair stations, training schools, or
training programs.
All certificate holders are required to develop Internal Evaluation Programs (IEP),
reference EAC 00-2, that continually monitor company policies and procedures to
ensure that the highest level of safety and compliance are maintained. To further
encourage the development and implementation of internal evaluation programs, the
ECASA has established the voluntary disclosure-reporting program. All certificate
holders that have established an internal evaluation program are afforded the benefits
applicable under this EAC. The ECASA will not recognize voluntary disclosure
procedures at any certificate holder that has not implemented an IEP.

EAC001.3 Related regulations

ECAR Parts 101, 121, 137, 141, 142, 145, and 147.

EAC001.5 Background
Civil penalties under the ECASA's enforcement program have always been considered a
means to promote compliance with the ECARs and not an end in themselves. Even though
deterrence is achieved by the appropriate use of civil penalties, public interest and safety
are also served by positive incentives that promote and achieve compliance.
The ECASA believes that providing incentives to any certificate holder that identifies
and corrects their own instances of noncompliance and invests additional resources in
efforts to preclude their recurrence enhances aviation safety.
It will be the ECASA's policy to forgo civil penalty actions when a certificate holder
detects and immediately discloses violations to the ECASA while taking prompt corrective
action to ensure that identical or similar violations do not recur. This policy is designed to
encourage compliance with the ECARs, foster safe operating practices, and promote the
development of effective internal evaluation programs.

EAC001.7 Key terms

The following key terms and phrases are defined to ensure a standard interpretation and
understanding of the Voluntary Disclosure Policy.
(a) Evidence: Evidence, as it related to this EAC is written documentation or reports
that support a certificate holder's analysis of the disclosed violation and the
elements of the proposed comprehensive fix. Evidence is generally derived from
the following:
(1) Review of documents or manuals;
(2) Examination of equipment;
(3) Activities observed; and
(4) Interview data.
(b) Comprehensive fix: An action plan, proposed by the certificate holder and accepted
by the ECASA, to preclude recurrence of the same violation. A schedule of dates
and events encompassed by the comprehensive fix must be established and
documented.
(c) Satisfactory fix: A comprehensive fix that has been satisfactorily implemented and
completed.

EAC001.9 Voluntary disclosure policy

The ECASA supports the open sharing of violation information and believes that a
cooperative spirit will enhance and promote aviation safety.
In lieu of civil penalty action for violations that are voluntarily disclosed to the ECASA,
certificate holders will receive a Letter of Correction. Once a Letter of Correction is
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Egyptian Advisory Circular Number 00-1 Egyptian Civil Aviation Supervisory Authority

issued, the case will be considered closed unless the certificate holder does not
satisfactorily complete the approved comprehensive fix.
In evaluating whether a disclosure is applicable under this policy, the ECASA will
ensure that the following conditions are met:
(One) The certificate holder discloses its noncompliance to the ECASA immediately
after detection and before the Authority learns of it by other means;
(Two) The actions leading to the disclosure were inadvertent;
(Three) The disclosure does not indicate a lack, or reasonable question, of the certificate
holder's qualifications;
(Four) Immediate action, satisfactory to the ECASA, was initiated upon discovery to
terminate the activity that led to the violation; and
(Five) The certificate holder has developed a comprehensive fix and implementation
schedule satisfactory to the ECASA. The comprehensive fix must include a follow-
up self-audit to ensure that the action taken corrects the noncompliance.
Note: Self-audits are in addition to any audits conducted by the ECASA.
Ordinarily, the ECASA will not forgo legal enforcement action if the certificate holder
informs the ECASA of a violation during, or in anticipation of, an ECASA
investigation/inspection or in association with an accident or incident.

EAC001.11 ECASA notification

The Voluntary Disclosure policy applies only when notification is made to the ECASA
upon discovery of the violation and before the ECASA learns of it by other means. This
initial notification must be made in-person or by telephone and accomplished within 24
hours of discovery.
Notification by the certificate holder: When notifying the ECASA, initial contact must
be made with, or directed to, the Head of Flight Safety Standards Sector and include the
following information:
(One) A brief description of the violation, including the duration of time it remained
undetected:
(Two) How and when it was discovered;
(Three) Verification that noncompliance ceased upon discovery; and
(Four) Verification that a detailed written report will be provided to the ECASA.
Note: The certificate holder shall send written verification of the above information to
the Head of Flight Safety Standards Sector within 7 calendar days following initial
notification.

EAC001.13 Certificate holder's report

A detailed report should be provided to the ECASA within 30 calendar days following
the certificate holder's initial notification to the Head of Flight Safety Standards. The
report must include the following information:
(One) A list of the specific ECASA regulations involved;
(Two) A description of the violation, including the duration of time it remained
undetected, as well as, how and when it was detected;
(Three) A description of the immediate action implemented to terminate the non-
compliance, including when it was taken, and who initiated the action;
(Four) An explanation that demonstrates the violation was inadvertent;
(Five) A detailed description of the proposed comprehensive fix outlining the planned
corrective steps, responsible parties for implementation, and a time frame for
completion; and
(Six) Identification of the company official responsible for monitoring the
implementation and completion of the comprehensive fix.

EAC001.15 Review by the ECASA

The ECASA and the certificate holder should work together to ensure that the
comprehensive fix is acceptable.
If the Head of Flight Safety Standards Sector determines that the proposed fix is
acceptable, a letter of correction will be issued to the certificate holder. This letter will
include the date that the comprehensive fix is scheduled for completion.
Following issuance of the Letter of Correction, the case will be closed, but remain
subject to reopening in the event that the certificate holder fails to comply with any element
of the comprehensive fix.

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EAC001.17 Comprehensive fix implementation

During the implementation period, the ECASA and the certificate holder should
continue working together. The ECASA may advise and assist the certificate holder in
correcting any identified systemic problems. Changes may be made to the corrective
action(s) when the certificate holder identifies a need and the ECASA concurs with the
change.
Note: The certificate holder must document any changes to the original comprehensive
fix and forward this information to the ECASA.
The ECASA will monitor implementation of the corrective steps. Throughout the
implementation period, the ECASA assesses the corrective efforts and management's
cooperation with these efforts. If it is determined that the steps taken are not those
documented in the comprehensive fix, the letter of correction may be rescinded, the
investigation reopened, and appropriate legal enforcement action may be initiated.
Following completion of the corrective action(s), the certificate holder conducts a self-
audit to ensure the deficiency that led to the violation has been resolved. Results of this
audit will be forwarded to the ECASA, within 7 calendar days following completion of the
comprehensive fix, so that they can make a final assessment. If all elements of the
comprehensive fix have been adequately accomplished, the Head of Flight Safety
Standards Sector will consider the fix satisfactory.

EAC001.19 Dispute resolution

When disputes occur regarding the acceptance or modification of a proposed
comprehensive fix, the Head of Flight Safety Standards Sector or the certificate holder’s
senior management may request that the Executive Chairman of the ECASA resolve the
issue. This procedure will provide for an independent assessment of the areas in
disagreement.

EAC001.21 Separate actions against pilots, engineers or other employees

The voluntary disclosure policy applies to individual pilots, engineers or other
employees of the certificate holder when:
(a) They are acting on behalf of the certificate holder and inadvertently violate the
ECAR's and;
(b) They immediately report the violation to their manager; and
(Three) The certificate holder immediately notifies the ECASA.
When all the above conditions are met, the ECASA will forgo punitive actions against
the individuals involved. If these conditions are not met, the ECASA will review the facts
associated with the case and determine appropriate action.
Note: The voluntary disclosure policy does not apply to matters concerning
qualifications to hold a pilot, engineer or other license issued by the ECASA.

EAC001.23 Repeated violations

The procedures outlined in this EAC may apply to the disclosure of a repeated violation
even though a comprehensive fix was satisfactorily completed. The determination of
whether a repeated violation is covered under this policy will be made by the ECASA
following an investigation of the associated facts and circumstances.

EAC001.25 Conclusion
The voluntary disclosure-reporting program, when used in conjunction with an internal
evaluation program, will help to ensure that actual and potential violations are promptly
identified, corrected, and reported to the ECASA.

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Egyptian Advisory Circular Number 00-1 Egyptian Civil Aviation Supervisory Authority

APPENDIX

REPORT FORMAT
The following format shall be used when preparing the mandatory detailed written
report that will be submitted to the ECASA. The certificate holder must include all the
elements specified in this report format.

EAC00.1aa.27 General
(a) Date.
(b) Certificate type or equivalent.
(c) Certificate number or equivalent.
(Four) Company name.
(e) Company address.
(Five) Company official filing report:
(1) Name.
(2) Position.
(3) Telephone number.

EAC00.1aa.29 Description of violation

(One) Applicable ECAR.
(Two) Date non-compliance was discovered.
(Three) Location of discovery.
(Four) Company official who discovered the violation:
(1) Name.
(2) Position.
(3) Telephone number.
(e) Date and time of initial notification to the ECASA.
(f) Name of ECASA official notified.
(g) Company official making notification:
(1) Name.
(2) Position.
(3) Telephone number.
Duration of time the violation remained undetected:
(A) Hours.
(B) Cycles.
(C) Days.

EAC00.1aa.31 Summary
The summary should be a brief statement describing the nature of the violation.
Additionally, it should identify the specific aircraft, engines, appliances, facilities, cargo,
and/or individuals associated with the non-compliance.

EAC00.1aa.33 Immediate action

(a) When the immediate action was taken to cease non-compliance.
(b) A description of the immediate action.
(c) Company official responsible for immediate action:
(1) Name.
(2) Position.
(3) Telephone number.

EAC00.1aa.35 Analysis
(a) A summary describing the scope of the violation and an explanation of its detection.
This summary should also describe the conclusions reached regarding possible
systemic deficiencies, i.e., who, what, when, why, and how the noncompliance
occurred.
(b) An explanation substantiating that the violation was inadvertent and the steps
initiated to determine the extent of the violation.
(c) An attachment with all the supporting documentation associated with the violation.

EAC00.1aa.37 Comprehensive fix proposal

A comprehensive fix includes the proposed long-term corrective actions that will be
implemented by the certificate holder to preclude recurrence of the violation. Each
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corrective step should identify the individual or department responsible for implementation
and completion.
NOTE: The certificate holder must include the date that it expects to complete all
corrective actions.

Questions or issues that a comprehensive fix proposal should address are:

(a) Did the violation involve equipment, facilities, or individuals beyond those
addressed in the initial notification?
(b) Are procedural or organizational changes necessary?
(c) How will the certificate holder determine that procedural or organizational changes
are effective?
(d) What procedures will be developed to ensure that the affected area is periodically
reviewed so that concerns can be identified before a violation occurs?
(1) Who will be responsible for performing these reviews?
(2) Who will receive the review results?
(3) How will the reviews be documented?

EAC00.1aa.39 Company official responsible for monitoring implementation of the

comprehensive fix
(a) Name.
(b) Position.
(c) Telephone number.
(d) Signature.

EAC00.1aa.41 ECASA acceptance (to be completed by the ECASA)

(a) Name.
(b) Position.
(c) Date.
(d) Office.
(e) Signature.

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