Comparative Analysis of the SAHPA Documentation

The landscape of recreational aviation governance in South Africa is undergoing a comprehensive transition from a legacy administrative model to a sophisticated, modular, and legally defensible regulatory framework. This transition is characterized by the replacement of the current documentation, primarily comprised of the Manual of Additional Procedures (MOAP) version 4 ¹ and the Manual of Procedures (MOP) revision 5 ¹, with a suite of proposed draft documents including the Memorandum of Incorporation (MOI) version 0.4 ¹, the Operations Manual (OM) version 0.7.2 ¹, the Manual of Procedures (MOP) version 0.5.2 ¹, and dedicated statutory compliance manuals for information governance.¹ This report provides an exhaustive comparative analysis of these frameworks, evaluating their documentation quality, linguistic consistency, alignment with the regulatory requirements of the Promotion of Administrative Justice Act (PAJA), the Protection of Personal Information Act (POPIA), and the Promotion of Access to Information Act (PAIA), and their response to critical judicial precedents such as Berwick v SAHPA.

Structural Transformation and Document Architecture

The primary observation in the evolution of the South African Hang Gliding and Paragliding Association (SAHPA) documentation is the shift from a monolithic and occasionally intertwined structure to a modular hierarchy. The legacy framework relies heavily on the Manual of Additional Procedures (MOAP), which functions as a repository for constitutional principles, binding rules of the air, and granular administrative steps.¹ This amalgamation has historically led to a lack of clarity regarding the hierarchy of authority, where procedural guidelines were sometimes relied upon beyond their intended mandate.²

The proposed suite addresses this by clearly separating governance authority, binding rules, and procedural execution into distinct instruments.¹ The draft architecture establishes the MOI as the primary corporate governance document, the Operations Manual as the source of binding operational and safety rules, and the Manual of Procedures as a non-rule-making technical guide for administrative execution.¹ This structural separation is a significant improvement in documentation quality, as it ensures that changes to procedures do not inadvertently alter governance principles and that any amendment to binding rules requires the rigorous approval process of the Operations Manual rather than the more frequent updates typical of a procedural manual.¹

Document Component	Legacy Framework (Current)	Proposed Framework (Draft)	Primary Purpose
Corporate Governance	Articles of Association (2005) ¹	Memorandum of Incorporation (2026) ¹	Defines the legal entity and director powers under the Companies Act.
Operational Authority	Manual of Additional Procedures (MOAP) ¹	Operations Manual (OM) ¹	Establishes the governance framework and binding rules for participants.
Administrative Execution	Manual of Procedures (MOP) Rev 5 ¹	Manual of Procedures (MOP) v0.5.2 ¹	Defines “how” functions are performed and recorded for ARO compliance.
Behavioral Oversight	Code of Ethics and Conduct (Annexure B) ¹	Code of Conduct and Just Culture ¹	Sets ethical standards and behavioral expectations.
Regulatory Interface	Combined MOAP / MOP ¹	Integrated Modular System ²	Aligns organizational functions with SACAA Part 149 requirements.

The transition from the current MOP Revision 5 ¹ to the draft MOP 0.5.2 ¹ also demonstrates an improved understanding of the Aviation Recreation Organisation (ARO) role. The current MOP focuses heavily on the internal quality assurance system and personnel requirements.¹ The draft MOP, however, is structured as a living administrative record, utilizing Addendums for information that is subject to frequent change, such as the personnel register, location records, and site lists.¹ This prevents the core manual from becoming obsolete due to personnel turnover or site changes, thereby maintaining its integrity as a stable regulatory interface.¹

Constitutional and Corporate Governance Shifts

The move from the 1973 Companies Act “Articles of Association” ¹ to a modern Memorandum of Incorporation (MOI) under the 2008 Companies Act ¹ represents a fundamental maturation of SAHPA’s legal status. The current Constitution identifies members as “subscribers” with personal rights that are non-transferable and terminate upon death.¹ The draft MOI, however, classifies SAHPA as a non-profit company (NPC) with no members as contemplated in Schedule 1 of the Companies Act.¹ This is a strategic legal shift designed to mitigate governance risks associated with membership-based litigation, common in sporting associations. Instead of “members” in the corporate sense, the draft MOI recognizes “National Members” solely for participation purposes, who are granted voting entitlements for the election and removal of directors but hold no proprietary or residual interest in the company.¹

This distinction provides the Board with the necessary autonomy to manage the organization in the public interest while preserving the democratic input of the pilot community.¹ The draft MOI also introduces more robust criteria for directors, requiring them to be “fit and proper” persons and establishing a three-year term of office, compared to the annual rotation suggested in the older documents.¹ This longer cycle supports strategic stability and the development of institutional expertise in aviation safety and regulatory liaison.¹

Furthermore, the financial governance sections in the draft MOI and Operations Manual introduce the concept of “Designated Strategic Funds”.¹ Unlike the legacy documents, which treat finances as a general bookkeeping task, the draft framework creates protected funds—such as a Safety Fund and a Strategic Reserve—that cannot be repurposed without a special resolution of the National Members.¹ This ensures that “Development Levies” and other targeted revenues are utilized for their intended purpose, enhancing organizational sustainability and member trust.¹

Governance Feature	Legacy Articles (2005)	Proposed MOI (2026)	Governance Impact
Legal Identity	Association Under Section 21	Non-Profit Company (NPC)	Aligns with modern South African company law.
Membership Status	Subscribers with personal rights	No members (Schedule 1); National Members for participation	Reduces corporate litigation risk while maintaining pilot input.
Director Terms	Annual rotation / re-election	3-year fixed terms	Enhances strategic stability and institutional memory.
Voting Rights	1 vote per member at AGM	Limited to election/removal of directors	Focuses member participation on board-level oversight.
Strategic Reserves	Not specified	Protected Strategic Funds	Safeguards funding for safety and development initiatives.

Linguistic Consistency and Professional Standard

A critical evaluation of the language across the current and proposed documentation reveals a profound shift from “club-house vernacular” to “regulatory prose.” The current MOAP and MOP often use informal phrasing and a mixture of first-person (“We”) and third-person perspectives.¹ The draft documents, particularly the Operations Manual, are written exclusively in authoritative third-person prose, using the imperative “shall” or “must” for binding rules and the descriptive “may” for guidance.¹ This linguistic rigor is essential for legal certainty, especially when rules are subjected to judicial or regulatory scrutiny.¹

The consistency of terminology is further enhanced by the introduction of a comprehensive “Defined Terms” section in the draft Operations Manual.¹ Terms that were historically used loosely, such as “Airmanship” and “For Reward,” are now given precise definitions.¹ “Airmanship” is codified as the “consistent exercise of sound judgement… that prioritises aviation safety and the public interest over technical compliance”.¹ This definition provides a much broader and more effective basis for safety oversight than the current Code of Ethics, as it allows the association to address behavior that, while technically legal, is fundamentally unsafe or brings the sport into disrepute.¹

The draft documentation also standardizes the terminology related to commercial activities. The legacy MOAP refers to “commercial loss” and “commercial paragliding” in disjointed sections.¹ The draft OM creates a definitive classification for “Commercial Tandem Operations,” which encompasses all tandem flights conducted for any form of reward, whether monetary or in-kind, and regardless of whether they are presented as “introductory experiences” or “training”.¹ This clarity is a direct response to the legal ambiguities highlighted in the Berwick judgment regarding the status of commercial paragliding at sites like Signal Hill and Hermanus.⁵

Alignment with Regulatory Requirements: PAJA, POPIA, and PAIA

The alignment with modern South African regulatory requirements is perhaps the most significant functional upgrade in the proposed documentation suite. The current MOP Revision 5 mentions that hearings should be conducted in accordance with the Promotion of Administrative Justice Act (PAJA), but it lacks a procedural framework for implementation.¹ The draft documents, by contrast, are built upon a foundation of administrative and information law compliance.¹

Administrative Justice (PAJA)

The draft Operations Manual (Part 17) and MOI (Section 6) explicitly recognize that SAHPA decisions—such as the withdrawal of site access, the refusal of license recognition, or the imposition of disciplinary sanctions—constitute administrative action.¹ This recognition triggers the mandatory application of PAJA principles, including the requirement for decisions to be lawful, reasonable, and procedurally fair.¹ The draft documentation mandates that affected individuals be given adequate notice of allegations, a fair opportunity to respond, and a written record of the reasons for the final decision.¹ This represents a major documentation quality improvement over the current MOAP Part 8, which allows for “verbal warnings” to be noted on member files without a structured procedural roadmap, a practice potentially vulnerable to legal challenge under the current administrative justice regime.¹

Information Governance (POPIA and PAIA)

The legacy documentation lacks a formal mechanism for the governance of personal information, which is a critical gap given the sensitive nature of medical certificates and accident data processed by an ARO.¹ The proposed framework introduces a dedicated PAIA and POPIA Manual ¹ that aligns with the Information Regulator’s 2025 updates.⁹ This manual maps data flows and assigns accountability to a registered Information Officer and Deputy Information Officers, ensuring that SAHPA’s compliance status is transparent and verifiable on platforms such as BizPortal.¹

The draft documentation also distinguishes between “Records Available Without a PAIA Request” (such as the MOI, OM, and MOP) and sensitive records requiring formal application.¹ This modularity ensures that SAHPA can meet its transparency obligations without compromising the privacy of its participants or the integrity of its safety investigations.¹ Furthermore, the introduction of unidirectional application programming interfaces (APIs) for the Membership Administration System (MAS) demonstrates a sophisticated technical approach to data protection, allowing schools to submit required data without gaining unauthorized access to the broader membership database.¹

Regulatory Framework	Legacy Status (Current)	Proposed Status (Draft)	Compliance Level
PAJA	Minimalist mention in Part 8 of MOAP ¹	Core principle in OM Part 17 and MOI Section 6 ¹	High – fully integrated procedural fairness.
POPIA	No formal policy or officer defined ¹	Dedicated Manual, IO appointed, data mapped ¹	High – aligns with 2025 Regulator guidelines.
PAIA	No defined request procedure ¹	Structured request protocol and records list ¹	High – standardizes access to information.
Part 149 ARO	Unified administrative document ¹	Modular oversight system ¹	High – aligns with SACAA ARO intent.

The Berwick Judicial Precedent and Public Interest Obligations

A defining feature of the proposed Operations Manual is its proactive response to the judicial findings in Berwick v SAHPA and Others.⁵ In that landmark case, the court affirmed that SAHPA, in its capacity as the body responsible for paragliding control, bears a duty of care to protect the public where it is aware of illegal aviation activities, particularly unauthorized commercial tandem operations.⁷ Judge Gamble noted that the legacy committee minutes reflected a measure of “ambivalence” towards the legal standing of commercial tandem flights, which the court found unacceptable for a safety-regulating body.⁵

The draft Operations Manual (Part 18) systematically addresses this ambivalence by codifying SAHPA’s duty to act in the public interest.¹ The rules now mandate that SAHPA take reasonable and proportionate steps when it becomes aware of conduct posing a risk to the public, including reporting such conduct to the SACAA and issuing public safety advisories.¹ This duty is held to apply regardless of whether the offending individuals are SAHPA members, a direct incorporation of the Berwick judgment’s reasoning.¹

This maturation of documentation quality is further evidenced by the clarity of the “Commercial Tandem Operations” rules in Part 13 of the OM.¹ Whereas the current MOAP refers to tandem flying in a mixture of technical and administrative contexts, the draft documentation clarifies that tandem flights conduct for reward are authorized only under a valid Part 141 Approved Training Organisation (ATO) or a Part 96 Commercial Operation certificate.¹ By removing the “ambivalence” noted by the court and creating a clear regulatory boundary, the draft documentation significantly strengthens SAHPA’s legal and professional standing.¹

Safety Culture and the Just Culture Paradigm

The transition from a “Code of Ethics” ¹ to a “Just Culture Framework” ¹ represents a major philosophical and operational shift in SAHPA’s approach to safety. The legacy Code of Ethics is largely aspirational, focusing on duties such as “beneficence” and “justice”.¹ While theoretically sound, such language provides little concrete guidance for managing specific safety breaches or near-misses.

The proposed Code of Conduct and the Safety Culture rules in the Operations Manual introduce the “Just Culture” model, which is international best practice in aviation safety management.⁸ This model recognizes that most unsafe acts are the result of human error or system flaws rather than deliberate misconduct.¹² Under the new framework, the association distinguishes between human error (which is met with support and system learning), at-risk behavior (which is met with coaching and corrective action), and reckless conduct (which is met with formal discipline and potential regulatory referral).¹

This model is supported by a “culpability matrix” and a commitment to protecting “good-faith reporting”.¹ The draft documentation ensures that members who report hazards or errors in good faith are protected from disciplinary action, a critical element for fostering a healthy safety culture where information flows freely.¹ This is a superior approach to the current Part 8 of the MOAP, as it focuses on the “what” and “how” of an occurrence rather than the “who,” thereby promoting systemic improvement across the entire recreational aviation community.¹

Behavior Classification	Definition in Draft Framework	Proposed Organizational Response
Human Error	Inadvertent slip or honest mistake; unintentional.	Consolation and system refinement.
At-Risk Behavior	Intentional shortcut or normalized deviation; increased risk.	Coaching, guidance, and training.
Reckless Conduct	Conscious disregard for safety or legality; unacceptable risk.	Discipline, sanction, and regulatory referral.

Comparative Analysis of Operational Governance Domains

The draft documentation suite provides a significantly higher level of granularity in its governance of specific operational domains, including site management, flight schools, and competitive events. The legacy MOAP often handles these domains with brief, high-level rules that leave significant room for interpretation.¹

Site Management and Environmental Stewardship

Current site rules in the MOAP focus primarily on grading and the registration of sites.¹ The draft Operations Manual (Part 11) introduces a comprehensive governance framework for “Site Custodians” and “Site Committees”.¹ A major documentation upgrade is the formal recognition of non-aviation site constraints, such as “Biosecurity Restrictions” and “Dune Rehabilitation Areas”.¹ These rules acknowledge that access to flying sites in South Africa is often contingent on environmental compliance and landowner relationships, and they codify SAHPA’s responsibility to enforce such non-aviation mandates.¹

The draft OM also addresses the complex issue of “site fees.” It prohibits clubs from levying compulsory charges on public land unless expressly authorized by the land manager, and it ensures that essential safety information for public sites is available without requiring membership or payment.¹ This alignment with “open access” principles for public resources is a major qualitative improvement over the legacy documents, which provide little guidance on the financial interaction between local clubs and visiting pilots.¹

Schools and Instructional Accountability

Under the current framework, flight training is mentioned primarily in relation to Part 141 and general license requirements.¹ The draft Operations Manual (Part 13) provides a much more nuanced definition of instructional authority and responsibility.¹ It introduces the concept of an “Enhanced Duty of Care” for instructors and explicitly prohibits “unattended student flying”.¹

Crucially, the draft documentation clarifies the regulatory boundary between SAHPA’s ARO oversight and the SACAA’s ATO oversight.¹ It confirms that while the SACAA is the sole regulator of training organizations under Part 141, the individual instructors remain SAHPA members and are therefore subject to SAHPA’s disciplinary framework regarding their conduct, professional standards, and adherence to Just Culture principles.¹ This “dual oversight” model ensures that behavioral issues which may not rise to the level of a Part 141 violation can still be addressed through the association’s governance processes.¹

Competitions and Organized Events

The current MOAP section on competitive flying focuses heavily on the administrative process of bidding for and staging national championships.¹ The draft Operations Manual (Part 16) shifts the focus towards safety management and institutional learning.¹ It mandates the appointment of a dedicated Safety Officer for all sanctioned events, who must be a senior pilot or instructor and may not participate as a competitor.¹ This ensures an independent and objective safety oversight that is separate from the competitive pressures of the event.¹ The new framework also introduces an “Event Organiser Checklist” ¹ that standardizes the emergency response and medical readiness requirements across all SAHPA-sanctioned activities.¹

Information Systems and the Membership Administration System (MAS)

The proposed documentation suite formalizes the role of the Membership Administration System (MAS) as the association’s “authoritative system of record”.¹ This is a significant infrastructure modernization. In the current documents, data handling and membership administration are described through fragmented procedures.¹ The draft OM, however, establishes the MAS as the official system for membership validity, safety reporting, and the recording of ratings.¹

A notable addition is the mandatory recording of all “Introductory Flight Experiences” conducted for reward in the MAS.¹ This register is intended to support safety monitoring, insurance validation, and regulatory cooperation.¹ The draft documentation also describes the governance of interfaces with third-party systems, ensuring that any data sharing is unidirectional and complies with the “purpose limitation” principles of POPIA.¹ This systemic approach to information governance ensures that SAHPA can provide verifiable data to insurers and regulators, thereby enhancing the overall credibility of the ARO.¹

System Record Type	Legacy Documentation	Proposed MAS Framework	Governance Link
Membership Status	General requirement to hold license.	Authoritative record of category and validity.	ARO Compliance
Safety Reporting	Forms on website / 7-day submission.	Structured digital submission / official record.	Just Culture
Tandem Activities	Not centrally recorded.	Mandatory IFE Register for flights for reward.	Liability / Insurance
Access Control	Not specified.	Role-based access and audit logging.	POPIA Section 19

Procedural Maturation in the new Manual of Procedures

The transition from the current MOP Revision 5 ¹ to the draft MOP 0.5.2 ¹ represents a shift towards evidence-based and dynamic management. The new MOP is designed to demonstrate SAHPA’s “means and methods for ensuring ongoing compliance” with its ARO approval conditions.¹ Unlike the legacy manual, which contained static descriptions of roles, the new MOP utilizes appendices to maintain current records of personnel, delegations, and site registers.¹

The draft MOP also introduces a detailed and robust “Recognition of Foreign Pilot Licences” procedure based on the International Pilot Proficiency Information (IPPI) card.¹ This replaces the somewhat vague “Acceptance” rules in the legacy MOAP.¹ The new procedure requires a verification of authenticity, a mandatory local conditions briefing, and, where recent experience is unclear, a supervised flight check by a qualified instructor.¹ This standardized approach ensures that foreign pilots are integrated into the South African safety system in a manner that is consistent, auditable, and acceptable to insurers.¹

Furthermore, the draft MOP includes a formal “Authorisation Register” and “Delegation Register”.¹ These registers provide a transparent record of exactly who has been granted internal authority for safety officer roles, accident investigation, or administrative coordination.¹ This transparency is a core requirement of CAR Part 149 and was largely absent from the current PDF documentation.¹

Comparisons of Specific Operational Procedures: Aerotow and Display Flying

A detailed comparison of the specific technical procedures contained in the legacy and proposed documents reveals a significant upgrade in instructional and safety standards.

Aerotow Procedures

The legacy Aerotow Manual (Annexure C of the MOAP) is a technical guide focusing on equipment configurations like bridle types and hand signals.¹ While technically accurate, it lacks a formal competency management framework. The proposed Aerotow Procedures (Appendix E of the MOP) shift the focus towards “Roles and Competencies”.¹ They establish a comprehensive competency framework for both tug pilots and hang glider pilots, including requirements for oral and practical assessments that must be recorded in pilot logbooks.¹ This transformation from a “how-to guide” to a “competency framework” reflects a maturation of SAHPA’s safety oversight role, moving away from simple technical instruction towards formal pilot qualification standards.¹

Display Flying and Airshows

In the current MOAP (Part 11), display flying is handled with a list of minimum hours and flights required for “Aerobatic” versus “Standard” displays.¹ The draft documentation suite elevates these requirements by linking them to the formal “Competence Management” section of the MOP.¹ The draft OM also clarifies the “Display Flight Plan” process, ensuring that any display activity is coordinated with the SACAA through a formal SAHPA-issued competence endorsement.¹ This ensures that display flying—which carries high public visibility and risk—is governed with the same administrative rigor as commercial tandem operations.¹

Quality Assurance and Competence Management

The legacy Quality Assurance System (QMS) in the 2022 MOP is focused primarily on biannual internal reviews and the documentation of non-compliances.¹ While functional, it is largely an administrative check.¹ The proposed QMS in the draft MOP (Section 15) is a risk-based system integrated with the association’s safety and disciplinary processes.¹ It recognizes that quality is not just about procedural accuracy, but about the effectiveness of the entire safety oversight system.¹

The draft documentation also introduces a formal “Competence Management” section for SAHPA personnel.¹ This requires that every person performing an ARO function, whether elected or appointed, undergo an initial assessment of competence and participate in periodic performance reviews.¹ This professionalization of volunteer roles is a critical component of meeting the SACAA’s 2025 strategic objectives for “strengthening compliance with international standards” and “fostering a culture of accountability”.⁴

QA Component	Legacy Framework	Proposed Framework	Organizational Benefit
Audit Scope	Focus on operational procedures and file accuracy.	Risk-based; covers governance, safety, and compliance.	Prioritizes high-risk areas for improvement.
Non-Compliance Tracking	Recorded in writing for consideration.	Categorized by significance; tracked through MAS.	Ensures evidence-based rectification.
Escalation Process	Direct to Accountable Manager.	Structured path to Board or SACAA where necessary.	Enhances accountability for systemic failures.
Competence Review	Annual re-election check.	Formal assessment and maintenance of skills.	Ensures key personnel are fit for purpose.

Language Consistency and Clarity: Final Observations

A final observation across the entire draft documentation suite is the meticulous effort to remove historical inconsistencies and regionalisms. The current MOAP and Constitution are laden with archaic terminology from the 1973 Companies Act and informal pilot slang.¹ The draft documents are written in a “global aviation English” that is consistent with ICAO standards and SACAA expectations.¹

This consistency extends to the numbering systems and cross-referencing. The draft Operations Manual and MOP use a standardized decimal numbering system that allows for precise reference to specific rules in disciplinary hearings or safety reports.¹ This level of documentation quality significantly reduces the risk of procedural errors during administrative actions and ensures that all participants have a clear understanding of their rights and obligations under South African law.¹

The proposed transition also effectively standardizes the “Statement of Non-Delegation” across all core documents.¹ This statement acknowledges that while SAHPA exercises significant oversight functions, it does not possess delegated statutory authority unless expressly granted in writing by the SACAA.¹ This serves as a vital legal shield, clarifying that SAHPA does not assume the statutory liabilities of the state and remains a self-administering airsport body.¹

Conclusion: Nuanced Implications for Future Governance

The comparative analysis of the legacy SAHPA documentation against the proposed draft framework reveals a strategic and necessary maturation of the association’s governance. The transition from the 2022/2024 manuals ¹ to the 2026 drafts ¹ is not merely an administrative exercise but a fundamental re-engineering of the organization’s legal and professional standing.

The legacy framework, while functional for its era, is characterized by structural amalgamations that created significant legal and regulatory vulnerability. Its inability to formally address POPIA and PAIA requirements, its ambivalence regarding commercial tandem operations, and its lack of structured administrative fairness under PAJA represented meaningful risks to the sustainability of the sport in a tightening regulatory environment.

The proposed framework provides a robust, modular, and legally defensible architecture. By separating authority from execution and incorporating international safety best practices such as the Just Culture paradigm, SAHPA positions itself as a modern ARO capable of protecting the interests of its members while discharging its duty of care to the public. The linguistic consistency, rigorous regulatory alignment, and sophisticated use of information systems like the MAS collectively represent an exhaustive upgrade in documentation quality.

For professional peers and regulators, the implications are clear: the proposed framework significantly enhances SAHPA’s ability to provide effective safety oversight, manage liability, and maintain regulatory confidence. The successful adoption of this framework will secure the operational future of recreational paragliding and hang gliding in South Africa by ensuring that the association operates with the same level of administrative rigor and legal integrity as the commercial aviation sectors it interfaces with.

Works cited

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