by Shawn Gauthier, Civil Aviation Safety Inspector, and Tim Stubbert, Civil Aviation Safety Inspector, National Aircraft Certification, Civil Aviation
Transport Canada’s General Aviation Safety campaign (GASC), recently transitioned to a General Aviation Safety Program. The goal of the campaign, now program, is to increase the overall safety of the general aviation sector in Canada. One of the offshoots of this program is the Voluntary Reporting Working Group. The Voluntary Reporting Working Group (VRWG) was established in June 2018 as part of the GASC. The original mandate of the VRWG was to:
- Research and develop a voluntary reporting system to be used by GA pilots; and,
- Research and develop a voluntary reporting system to be used by Flight Training Units.
The topic of Service Difficulty Reporting (SDR) joined the working group’s conversations and was immediately identified as an important component to GA safety and viability. Service Difficulty Reporting provides Transport Canada and other civil aviation authorities an essential view of the health and safety of the aircraft flying in our skies.
General aviation being the largest sector of aviation in Canada, one would think that Transport Canada would have tremendous amounts of SDR data to comb through to discover trends in GA aircraft failures, malfunctions and defects. They do not. GA SDR reporting is the least frequent when compared to all other sectors of aviation in Canada. Service Difficulty reporting is also not mandatory for GA. But does that make it any less important? TC says no. Let's take a look at what an SDR is and what the SDR system is comprised of in order to get a better understanding.
Service Difficulty: failure or malfunction of, or defect in, an aeronautical product.
Aeronautical Product: aircraft, aircraft engine, aircraft propeller or aircraft appliance or part, or a component part of any of those things.
Reportable Service Difficulty: a service difficulty that affects or that, if not corrected, is likely to affect the safety of an aircraft, its occupants or any other person.
From the definitions above you can see that, if it is attached to an aircraft and it is likely to affect safety, it is a reportable service difficulty, and TC would love to hear about it.
TC has published Advisory Circular AC 521-009 to help the Canadian aviation community better understand the SDR system. The AC gives examples of reportable defects and help for submission.
Here is an example of a submitted Canadian SDR.
SDR 20160502010 - PIPER PA28 140
PART NAME: YOKE PART NUMBER: 6201903
PILOTS CONTROL YOKE UPPER L/H SIDE, CLOSE TO WHERE THE PUSH TO TALK SWITCH IS MOUNTED, CRACKED ALL THE WAY THROUGH IN FLIGHT, THE YOKE REMAINED INTACT AND THE AIRCRAFT WAS CONTROLLABLE. CRACK IS NOT IN THE AREA OF INSPECTION REQUIRED BY AD 69‑22‑02 AND PIPER SB 527D
This example displays the perfect SDR submission. The submitter provides the part name, number and a great description of what the event entailed. Additionally, the submitter ties in an existing Airworthiness Directive and Service Bulletin related to similar defects noted in the SDR.
Continuing Airworthiness, In-Service Investigation division of the National Aircraft Certification branch of Transport Canada Civil Aviation is responsible for all SDRs submitted in Canada. In 2019 there were 4 727 SDRs submitted to TC from Canadian owners, operators, maintainers and AMOs.
In-Service Investigation has seven Corrective Action Technical Inspectors (CATI) that review every Service Difficulty Report that is submitted either through the Web Service Difficulty Reporting System (WSDRS) or by fax/paper submission. These Technical Inspectors (CATIs) are divided by product, product type, and by type certificate holder. When an SDR is submitted, the CATI responsible for that product reviews it for completeness and overall safety impact. When the review is complete, the CATI then forwards the SDR to the type certificate holder responsible for the subject aeronautical product. As an example, an SDR submitted for a Cessna 172 would be reviewed and forwarded to Textron Aviation. This process is the same for engines and propellers.
What does TC do with all those SDRs? Routinely, SDRs materialize into larger projects. For TC, SDRs are often the corner stone of Airworthiness Directives, Civil Aviation Safety Alerts (CASA) and Feedback Articles—all forms of Corrective Action. The Service Difficulty reporting program provides for the collection, organization, analysis, and dissemination of aircraft service information to improve service reliability of aeronautical products. It is one of the most important tools TC has to gauge the safety and reliability of Canadian registered aircraft. Regularly, the above mentioned CATIs perform analysis on the SDR data to discover trends in the defects submitted.
In addition to Canadian SDRs, the WSDRS database contains SDRs submitted from the United States and Australia. In total there are over 1 937 336 SDRs in the database. The CATIs work closely with TC's Continuing Airworthiness Corrective Action Engineers to determine if the rate and severity of the reported defects match TC's definition of an unsafe condition. This is when an Airworthiness Directive is created. Down the severity scale, a CASA is the next publication that can originate from SDRs. A CASA is used to convey important safety information and contains recommended action items. A CASA is not mandatory like an AD, but the actions contained within are highly recommended. The third tier is a Feedback Article. Feedback articles are a safety awareness communication tool used by TC for the aviation community. These articles are directly created from submitted SDRs and chosen by the above CATIs as events of interest.
In addition to Transport Canada’s corrective action options outlined above, SDRs are routinely utilized by the Type Certificate Holder to initiate a corrective action or product improvement. These may be in the form of Service Bulletins, Information Letters, or Instructions for Continued Airworthiness (ICA) updates just to name a few.
A good way to think of the impact SDRs have on safety is to compare them to a TSB report. A TSB accident report is reactive in nature, where SDR reporting is proactive risk management. The main objective is to get ahead of the defect.
How does general aviation tie in to all of this? SDR reporting is not mandatory for GA. It also isn't mandatory for AMEs. Who is required to submit? As per the Canadian Aviation Regulations, the following are required to submit SDRs:
- CAR 573—Aircraft Maintenance Organizations (AMO);
- CAR 406—Flight Training Units (FTU);
- CAR 706—Air Operators;
- CAR 604—Private Operators;
- CAR 521—Design Approval Holders, and
- CAR 561—Manufacturers of Aeronautical Products.
Who can submit SDRs? Anybody. Transport Canada allows for the submission of SDRs by any person who feels the need exists to submit. The WSDRS is the quickest way to submit, but fax and mailing of an SDR is always welcome.
- SDR Form 24-0038 is available through Transport Canada’s Forms Catalogue.
- Access to the WSDRS system.
The WSDRS website contains many other useful links. A user can gain access to Airworthiness Directives, CASAs, Feedback magazine website link and access to the fax/paper copy of the SDR form. Owners and maintainers may also find an added benefit of the system by using the immense data base of SDRs to search for submissions for their product type. These submissions may contain useful defect rectification techniques used by the submitter to rectify a similar defect.
What is the direct benefit to GA community? Improved safety. SDRs simply improve the safety of you, the operator of GA aircraft, and of the entire worldwide aviation community.
In closing, Transport Canada's Service Difficulty Reporting System is highly recommended for all members of the aviation community. For the general aviation and AME sector it is completely voluntary, but it provides a valuable tool to help keep aviation safe in Canada.