Aviation Related Concern (ARC) Procedure
___________________________________________________________________________
1. Purpose
The purpose of this procedure is to guide and direct the Authority on how it triages and investigates
Aviation Related Concerns (ARC).
2. Scope
The procedure applies to ARCs received by the Inward Safety Information team that have been
determined that an investigation is required. It excludes non-aviation related concerns and other
general complaints.
3. Definitions
Aviation Related Concern (ARC): Information provided to the Authority by a submitter that believes
an issue they have witnessed or ascertained is a concern relating to aviation safety, aviation security,
Healthy and Safety at Work Act 2015 (HSWA) or Hazardous Substances and New Organisms Act 1992
(HSNO) practices. Does not include occurrences captured by the mandatory reporting requirements
set out in Civil Aviation Rule Part 12 or as required by section 56 of the HSWA.
Submitter: Person or organisation that raises the ARC to the Authority. The submitter can be a
member of the public, an aviation participant, Authority staff or other government organisations.
Subject: Individuals, organisations or aircrafts focus of the concern.
Occurrence Database: Module of the ASMS business system where occurrences (including concerns)
are recorded.
Investigation Memo: An internal document used to summarise an ARC investigation; its contents
should not be disclosed to parties outside of the organisation.
4. Key responsibilities
Manager Investigation and Response: Overall responsibility for the ARC process. Maintain oversight
of the process to ensure performance and quality standards are met.
Team Leader Occurrence Team Investigation and Response / Manager Aeronautical Services /
Manager Security Regulatory: Assign resources to and coordinate the investigation related to their
area of responsibility (described below). Maintain oversight throughout the investigation to ensure it
is carried out according to good practice and based on the principles outlined in the policy. Provide
advice and support during the investigation.
Inward Safety Information Team (ISI): Responsible for receiving, triaging, classifying, and
documenting all concerns and related information which may result in an ARC Investigation.
5. Process
The process map that outlines this process can be found in Annex 1.
Information about each step of the process is outlined below.
Author: C. Gooch / J. Harland
Effective date: 01/08/2021
Page 1 of 9
QA Approver: Y. Bartholomew
InfoHub ID: 36524461
Revision 3.0
Approver: D. Cooze
Owner: D. Cooze
5.1
Receipt and recording of concerns
Concerns can be raised via email, internet form, phone, face to face or mail. Regardless of how an
ARC is received the ISI team will:
• Collect and record information and details of the concern by logging an ARC type occurrence
in the occurrence database.
• Classify the ARC Occurrence using the ARC Descriptor (se
e ARC Descriptors – Descriptions
and use guidelines)
• Contact the submitter of the information to get all required details if incomplete.
Where possible, the following information for an ARC should be gathered:
• Name and contact information of the submitter (unless they wish to remain anonymous).
When there is more than one submitter, information of all submitters should be included in
the occurrence. When Authority staff forward concerns to Inward Safety Information, the
original submitter should be recorded, not just the staff member.
• Location of the concern where applicable (note some concerns do not have a specific single
location).
• Identification of the organisation, person, or system about which there is a concern (where
available). This may be a company, a person’s name, or a participant ID.
• Date and time of any specific matter of concern where applicable.
• Description of the event that gave rise to the concern.
• What is the safety concern?
• Whether the submitter wishes to be notified of the outcome.
All steps undertaken by the Inward Information to gain further information regarding the ARC,
including phone calls to and from the submitter, should be outlined as log entries in the occurrence
database.
5.2
Triage of concern
Once the ARC has been loaded into the occurrence database the Inward Information then complete a
triage of the ARC by reviewing the information and deciding on how to proceed based on the
following:
Does the ARC fall within the Authority’s jurisdiction?
Should the matter be referred to another agency to take primacy?
Is it possible to identify the individual/aircraft or company subject of the concern?
Inward Information will assess the safety risk to decide if an investigation is required and identify the
appropriate unit to carry out the investigation. They will seek advice from other units where
necessary.
Possible outcomes of the triage are:
• No further action: If an investigation is not considered appropriate, then the decision taken
and reason as well as any information and documentation relating to the concern shall be
saved in the occurrence database (through an occurrence log entry). Where possible, the
submitter should be notified.
Examples of decisions recorded are: No further action – breach of privacy by drone operator
does not fall within the Authority’s jurisdiction; No further action – not enough information
Author: C. Gooch / J. Harland
Effective date: 01/08/2021
Page 2 of 9
Quality approver: Y. Bartholomew
Revision: 3.0
Approver: D. Cooze
Owner: D. Cooze
to proceed with investigation; No further action - referred to NZQA as the matter relates to
welfare of students.
• ARC Investigation required: If the decision is to trigger an investigation, then Inward
Information will raise a Work Request (WR) in the business system after attempting to
capture all information as outlined above (in some cases not all information will be able to be
gathered prior to a WR being raised).
If the assessment determines that the concern represents an immediate impact to safety, the issue
should be raised with the appropriate Unit Manager as soon as practicable in addition to the creation
of the ARC WR.
5.3
Raising a Work Request
The WR type will be determined based of the area of responsibility as outlined in the below table:
ARC WR type –
Area of responsibility
Responsible unit
ARCA - Aeronautical
Aeronautical Services investigates ARCs that relate to:
Services Unit (ASU)
• Air traffic Service
• Airspace Hazards
• Aerodrome Operations
• Airspace Designation
• Aeronautical Information
• Navigation Aids
• Provision of Meteorological Services
ARCS – Security
Security Regulatory investigates ARCs that relate to:
Regulatory Unit (SRU)
• Aerodrome
• Air operator
• Air traffic service organisation
• Regulated Air Cargo Agent (RACA)
• Aviation security provider
ARCG – Occurrence
All other aviation safety and health and safety related concerns,
Investigation Team (IRU)
including but not limited to:
• Remotely Piloted Aircraft (RPAS)
• Agricultural operations
• Pilots and licencing
• Airworthiness and aircraft maintenance concerns
• Aircraft operation concerns, etc.
Upon creation, WR will remain in state OPENED in the system.
When an ARC WR is created, any information and documentation relating to the occurrence shall be
saved in the appropriate InfoHub folder as soon as possible after the ARC WR has been raised
(InfoHub folder is automatically created when the WR is opened).
5.4
Manager/Team Leader Review (WR in state OPENED)
The relevant Manager/Team Leader (based on the WR type created) will receive an email notifying
them that ARC WR has been raised (in addition, the list of open WR can be obtained directly from the
business system).
Author: C. Gooch / J. Harland
Effective date: 01/08/2021
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Quality approver: Y. Bartholomew
Revision: 3.0
Approver: D. Cooze
Owner: D. Cooze
At this stage, the relevant Manager/Team Leader will conduct an initial review of the information
provided in the concern to assess the risk presented, determine the risk priority rating and assign
appropriate resources to carry out the investigation.
5.4.1
Determine risk priority
Questions to consider during review:
Are there risks or practices that require immediate intervention?
The initial review should establish the nature of the risk presented, which guides the urgency and
scope of the Authority’s response. Where required, the concern can be escalated, and other
regulatory action may be initiated.
Does the concern fall within their unit regulatory oversight responsibilities?
If the concern falls outside of the Authority’s jurisdiction but may be of interest to another agency,
the Manager/Team Leader will ensure the information is referred to the appropriate agency
identified, and then cancel the WR noting the actions taken. If the submitter has provided contact
details, they must be notified of the decision.
If the concern is more applicable to another unit within the Authority, the Manager/Team Leader will
engage with the Inward Information to ensure the appropriate WR is created before cancelling WR.
The risk priority rating determined in the review should be recorded in the appropriate field in the
business system. The initial review activity, communications, and any decisions made should be
recorded in the ARC WR through the log notes.
5.4.2
Allocation of resources and scoping of ARC
Based on the above, the Manager/Team Leader will assign staff members to the following roles in
the ARC WR:
• Investigator: person in charge of carrying out the investigation and make recommendations
on further steps to be taken.
• Peer Review: person in charge of reviewing the investigation, reviewing appropriateness of
the recommendations made, and close the WR once the actions have been taken.
The Managers/Team Leader can assign themselves as Investigator or Peer Review, but cannot have
both roles in the same investigation.
The staff members assigned must be informed that they have been added to the WR and provide
guidance as to the scope of the investigation (this can be done using the “Send Mail” function in the
business system).
At this point the WR will automatically change to state ASSIGNED.
5.5
ARC Investigation (WR in state ASSIGNED)
The staff member assigned as investigator is responsible for investigating the concern in accordance
with best practice. This involves reviewing all the information regarding the ARC from the occurrence
database, the ARC WR, the InfoHub folder, and where practicable gathering any other relevant
information. The investigator can seek guidance or advice from the Manager/Team Leader if
necessary.
During the investigation all investigation steps, progress made, enquiries undertaken, and other
relevant information should be recorded in the system through log notes, as they occur. All evidence
and relevant material to support the decisions should be appropriately saved in the relevant ARC
InfoHub folder (see section 6)
Author: C. Gooch / J. Harland
Effective date: 01/08/2021
Page 4 of 9
Quality approver: Y. Bartholomew
Revision: 3.0
Approver: D. Cooze
Owner: D. Cooze
When waiting for information, it is expected that the investigator will follow up progress at least
every 30 days and reflect this into the log notes.
If corrections or updates to the occurrence need to be made (e.g. participant name/number, aircraft
registration etc.), the investigator should arrange the amendment of the occurrence by notifying
Inward Information by email ([email address]).
If during the investigation the information reveals that the depth of investigation required is beyond
the scope of the ARC process (including information indicating an immediate, major, or critical threat
to aviation safety or security), the investigator shall escalate the case by promptly notifying the
Manager/Team Leader, who will decide on what action or intervention to take. The decision must be
documented and saved to the work request log and any associated information saved in InfoHub.
If assistance or input from a subject matter expert (SME) is required, the investigator should bring it
to the attention of the Manager/Team Leader. They will request resources to the appropriate unit
and assign the designated staff to the WR under the role of Technical Specialist. The level of
involvement of the SME can vary from providing advice to the investigator, analysing evidence to
conducting interviews or part of the investigation, however, the investigator is still responsible for
carrying out the investigation.
5.5.1
Investigation findings and recommended outcome
Once the investigation is completed, the investigator should record their findings and make a
recommendation on the actions to take using th
e Investigation Memo. If the investigation reveals
that it is a low risk event and is unlikely to result in an enforcement administrative outcome, findings
and recommendation can be recorded in a log entry note in the system instead of in an Investigation
Memo.
The recommendation should be in line with the principles included in the Authority’s regulatory
practice guidance documents. The potential recommended outcomes of an investigation are:
• No further action (NFA): The investigation cannot be completed due to lack of enough
information or evidence; therefore, no further action can be taken by the Authority.
• No offence disclosed (NOD): Investigation has been completed and no offence has been
disclosed. No further action will be taken by the Authority.
• Educational material/advice (EA): Educational letter, material or advice to be provided to the
subject.
• Warning letter (WW): Issue a formal warning letter. This situation requires an ENI WR type to
be created prior to the closure of the ARC WR.
• Enforcement action (IN): infringement notice or prosecution action. This situation requires an
ENI WR type to be created prior to the closure of the ARC WR.
• Refer to another unit or agency (ROA): Refer to another unit for further work (e.g. special
purpose audit, spot check, etc.). If further work from the Authority is recommended, the
appropriate WR should be created prior to the closure of the ARC WR.
Once the investigation is completed, and findings and recommendations recorded, the WR should be
referred to the staff assigned as Peer Review for review and approval. At this point the investigator
should change the state of the WR to ASSESSMENT and notify the peer reviewer (this can be done
using the “Send Mail” function in the business system).
5.6
Review and approval of investigation (WR in state ASSESSMENT)
The staff assigned as Peer Review will review the Investigation Memo (where applicable), the log
notes and any supporting evidence to assess if the investigation was completed to the required
standard and using appropriate judgement, and confirm that they agree with the recommendation.
Author: C. Gooch / J. Harland
Effective date: 01/08/2021
Page 5 of 9
Quality approver: Y. Bartholomew
Revision: 3.0
Approver: D. Cooze
Owner: D. Cooze
The depth of the review will depend on the level of risk identified and complexity of the
investigation.
If the peer reviewer believes further enquiries are needed or disagrees with the recommendation,
they will feed back on the outcome of the review and refer the case back to the investigator. In this
case the state of the WR should be changed back to ASSIGNED.
If the peer reviewer agrees with the recommendation and is satisfied the investigation has been
completed to the required standard, the peer reviewer will record the confirmation and reasons in
the WR log notes, change the WR state to ASSESSED and instruct the investigator to complete
recommended actions and closure tasks (this can be done using the “Send Mail” function in the
business system).
If the recommendation involves further actions (e.g. warning letter, infringement notice, audit spot
checks etc.) the way forward should be decided in consultation with the appropriate Unit Manager. If
a regulatory enforcement investigation is necessary, a referral shall also be made in consultation with
the Manager Investigation and Response Unit (IRU). An appropriate WR should be raised before the
closure of the ARC WR.
5.7
Complete closure tasks and update submitter (WR in state ASSESSED)
Where practical the investigator must update the submitter (and where appropriate, the subject) as
to the outcome of the investigation keeping in mind any potential breach of The Privacy Act 2020.
The submitter should be advised of the outcome even when the decision is not to take further
actions. This should be recorded in the ARC WR log notes with a brief explanation of what the
submitter was told and/or reference to the correspondence saved in InfoHub.
Once approved by the peer reviewer, the investigator should:
• complete the Investigation Memo (where applicable) including any corrections made in the
review stage,
• ensure all relevant log notes are entered in the system and all evidence and relevant
documents are appropriately stored in InfoHub,
• carry out the actions recommended in the Investigation Memo (e.g. provide educational
material or advice to subject) if these haven’t been done already,
• include reference in the WR log notes to any other WR created if further work is required,
• refer to the appropriate unit if any additional safety risk identified.
The file completion checklist can be used to reflect the completion of these actions. Once completed,
the WR state should be changed to NOTIFIED for final check and closure.
5.8
Closure of work request (WR in state NOTIFIED)
Before closing the WR, the peer reviewer will do a final review to check that the actions have been
taken, all relevant parties have been contacted, and documents and information has been
appropriately recorded.
The peer reviewer will then proceed to close the WR using the appropriate closure code based on the
outcome of the investigation (further guidance is availab
le in ARC investigation outcomes -
Guidance):
•
Closed-NFA: Unable to complete investigation (e.g. due to lack of information)
•
Closed-NOD: (no offence disclosed) investigation completed, no breach or safety risk was
identified and no action was taken by the Authority.
•
Closed-EA: educational material, advisory letter or advice was provided to subject.
•
Closed-WW: Warning Letter issued. ENI work request created.
Author: C. Gooch / J. Harland
Effective date: 01/08/2021
Page 6 of 9
Quality approver: Y. Bartholomew
Revision: 3.0
Approver: D. Cooze
Owner: D. Cooze
•
Closed-IN: Enforcement action to be taken (e.g. infringement notice, prosecution, etc.). ENI /
ENP work request created.
•
Closed-ROA: referred to other unit for further work (special purpose audit, spot check, etc.).
Appropriate work request created.
6. Recording of activity
Information recorded should ensure that:
• Decisions are informed, evidence-based and capable to withstand future scrutiny.
• The results of the investigation are available to the Authority for future considerations.
• Transparency, impartiality fairness and consistency of decisions can be demonstrated.
Due to the varied nature of ARCs and the associated investigation, the following repositories are
used to record information:
• WR log notes: the business system is used to record all investigative steps taken throughout
the investigation. All staff involved in the investigation should record their steps in the log
notes.
• Investigation Memo: this document is used to record the findings of the investigation,
recommendations and decisions as well as the rationale behind those.
• InfoHub folder created for the investigation: this folder is used to store evidence and other
relevant information to support the decision.
The following information must be saved:
• Evidence of communication with the submitter (where appropriate).
• Documentation, information, letters, referrals, etc. and pieces of evidence that were made
and part of the investigation or recommendation process (provided as part of the concern or
collected throughout the process of the investigation).
• Investigation findings and recommended actions (Investigation Memo).
• Evidence of any correspondence generated throughout the process of the investigation or
related to the concern (internal communications generated done using the “Send Mail”
function in the business system are automatically included in the log notes in the system).
7. Related documents
•
Investigation Memo template
•
ARC Descriptors – Descriptions and use guidelines
•
ARC investigation outcomes - Guidelines
•
Quality Attributes – ARC quality reviews
•
Regulatory Operating Model (ROM)
•
Aviation Related Concern Policy
8. Relevant Legislation
• Civil Aviation Act 1990
• Civil Aviation (Offences) Regulations 2006
• Health and Safety at Work Act 2015
• Hazardous Substances and New Organisms Act 1996
• Regulatory Operating Model
• Use of Regulatory Tools
Author: C. Gooch / J. Harland
Effective date: 01/08/2021
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Owner: D. Cooze
• Criminal Procedure Act 2011
• Summary Proceedings Act 1957.
9. Measure of effectiveness
The effectiveness of this procedure will be measured by:
• % ARC work requests closed within 180 days of raised
• % ARC work requests closed within one year of raised
• % of ARC work request that comply with the following quality attributes:
o Timeliness
o Appropriate judgement
o Documents and evidence saved appropriately
o Decision and reason appropriately recorded
o Complainant notified of the outcome (where appropriate)
10. Document Control
Title
Aviation Related Concern (ARC) Procedure
Effective date
01/08/2021
Christopher Gooch (Team Leader Occurrence Investigations)
Author
Jenny Harland (Technical Support Investigation and Response)
Approver
Dianne Cooze (Manager Investigation and Response Unit)
Quality approver
Yvette Bartholomew (Advisor Quality Systems)
Operational Policy
Jordan Thorstensen (Advisor Operational Policy)
Owner
Dianne Cooze (Manager Investigation and Response Unit)
Revision
3.0
Review date
01/08/2024 (3 years from effective date)
InfoHub ID
36524461
Revision
Date
Description of change
2.0
July 2021
Process and procedure adapted to new operating environment.
Typos corrected. Minor rewording for greater clarity. Reference to
3.0
11/11/2021
outcome classification guidance document added.
Author: C. Gooch / J. Harland
Effective date: 01/08/2021
Page 8 of 9
Quality approver: Y. Bartholomew
Revision: 3.0
Approver: D. Cooze
Owner: D. Cooze
Annex 1: Process diagram
Aviation Related Concerns (ARC) process map
date: 01/06/2021
OPENED
ASSESSED
ASSIGNED
ASSESSMENT
NOTIFIED
(prioritisation and
(implement
(carry out investigation)
(review and approval of investigation)
(final check and closure)
resource allocation)
recommendations)
Receive concern
This includes H&R related
ARCA: Aeronautical Services
concerns
ARCG: Aviation Safety
ARCS: Security Regulatory
n
oita
rm
Collect information
Does it require
of
and log ARC
further
Yes
Raise ARC WR
nI
occurrence
investigation?
rdawnI
No
Update information in
Update Occurrence
Save relevant
occurrence database.
Cancel WR and create
End
Inform compliant NFA
information in IH
Add log
correct one
from CAA
folder
Email ISI to cancel and raise
Review information
If the concern requires
correct WR
immediate action the case should
be escalated
Yes
r
Change WR status to
e
Does this need re-
Can be
d
"
CANCELLED"
No
No
a
entering?
investigated?
e
adding reasons in WR log
L
ma
Te /
Yes
r egana
Assign risk priority
M
Assign Staff:
•
Investigator
•
Peer Review
Notify staff
Review information and
Closing codes:
Contact submitter to
carry out investigation
inform outcome
•
Closed-NFA: Unable to complete
Update WR log
Request update to
investigation (e.g. due to lack of information)
Inward Information via
•
Closed-NOD: (no offence disclosed)
This can be request the creation of a further WR (e.g. spot
Update WR log with
email
check, SPA, ENI), provide educational material/advice, etc.
investigation completed, no breach or safety
investigative steps
Note: in some cases this is done throughout the process of
Implement actions
risk was identified and no action was taken
Save documents in
r
the investigation.
(or coordinate
by CAA.
o
InfoHub
Yes
implementation)
•
r
t
Closed-EA: educational material, advisory
o
a
t
g
letter or advice was provided to subject.
a
it
gi s
•
Closed-WW: Warning Letter issued. ENI
t
e
s
v
e
n
Complete
work request created.
v
I
n
:
SME input
Does Occurrence
Investigation Memo
Complete self-check
•
I
e
Closed-IN: Higher enforcement action to be
l
No
No
required?
need updating?
(I.M.)
form and save it in IH
taken (e.g. infringement notice, prosecution,
Ro
folder
etc.). ENI / ENP work request created.
•
Closed-ROA: referred to other unit for
Yes
further work (special purpose audit, spot
check, etc.). Appropriate work request
Request addition
created.
of SME to relevant
Change state to
Review feedback and
Change state to
NOTIFIED
Manager / Team
ASSESSMENT
amend investigation
Notify Peer Reviewer
Leader via email
Notify Peer Reviewer
Change state to
Review I.M. and
ASSESSED
recommended actions
Arrange involvement
Notify Investigator
Review investigation
Change state to a
r
This task can be done by Administrators, the
e
of SME with relevant
checklist, WR and
closed state based on
w
Team Leader or anyone with access to
unit manager
actions taken
outcome
ei w
Administer WR
v
ei
re
v
Note: Administrator role in the WR
r
e
State approval in I.M.
e
R
doesn t need to be set to do this.
Accepted?
Yes
e
r
and log in WR
P e
/
r
Pe
e
:
v
el
Assign SME as
ro
No
p
Ro
"
Technical Specialist"
p
A
Change state back to
Add log in WR / add
ASSIGNED
comments to I.M.
Notify Inspector
laci
The involvement of the Technical Specialists can vary
n
tsi
E
h
l
from advice, carry out part of the investigation
c
ai
(requesting and analysing information) to interviewing
SM
Te
c
Provide support
:
e
e
and inspecting.
l
Sp
Update WR log
Ro
Author: C. Gooch / J. Harland
Effective date: 01/08/2021
Page 9 of 9
QA Approver: Y. Bartholomew
InfoHub ID: 36524461
Revision 3.0
Approver: D. Cooze
Owner: D. Cooze
