SUMMARY REPORT ON THE SAFETY OVERSIGHT AUDIT FOLLOW-UP OF THE DEPARTMENT OF CIVIL AVIATION OF BOTSWANA

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1 ICAO Universal Safety Oversight Audit Programme SUMMARY REPORT ON THE SAFETY OVERSIGHT AUDIT FOLLOW-UP OF THE DEPARTMENT OF CIVIL AVIATION OF BOTSWANA (Gaborone, 7 to 9 November 2001) International Civil Aviation Organization

2 ICAO UNIVERSAL SAFETY OVERSIGHT AUDIT PROGRAMME Summary Report on the Safety Oversight Audit Follow-up of the Department of Civil Aviation of Botswana (Gaborone, 7 to 9 November 2001) 1. INTRODUCTION 1.1 Background The Department of Civil Aviation (DCA) of Botswana was initially assessed under the voluntary ICAO Safety Oversight Assessment Programme from 23 to 27 June 1997 by an ICAO assessment team. Subsequently, an audit was carried out from 17 to 23 November 1999 pursuant to Assembly Resolution A32-11 and in accordance with the updated Memorandum of Understanding (MOU) agreed to on 21 May 1999 between Botswana and ICAO. The objectives of the audit were twofold. Primarily, its objective was to fulfill the mandate given to ICAO pursuant to the above-mentioned Assembly Resolution. Secondly, the audit was conducted with the objective of ascertaining the progress made in the implementation of the recommendations forwarded during the voluntary assessment conducted in 1997 and to re-ascertain the safety oversight capability of the DCA of Botswana. The audit also aimed at ensuring that Botswana is in conformity with ICAO Standards and Recommended Practices (SARPs), as contained in Annexes 1, 6 and 8 to the Convention on International Civil Aviation (Chicago Convention) and related provisions in other Annexes, guidance material and relevant safety-related practices in general use in the aviation industry On 28 February 2000, Botswana submitted a corrective action plan addressing all the findings and recommendations contained in the audit interim report and also containing comments and clarifications of some of the items. The action plan submitted was reviewed by the Safety Oversight Audit (SOA) Section and was found to be satisfactory. On 30 March 2000, Botswana submitted additional information on implementation dates of some items. The action plan, comments and clarifications provided were taken into consideration in the preparation of the final and summary reports. The summary report was distributed to all Contracting States by State letter AN 19/1-00/69 in June Objectives and activities of the audit follow-up mission This audit follow-up mission was conducted in accordance with Article 18 of the MOU. The objective of this mission was to validate the implementation of the corrective action plan and to ascertain the status of the progress made, which enables ICAO to update the information contained in the audit findings and differences database (AFDD) and also to inform other Contracting States on the status of the safety oversight system of Botswana through a non-confidential summary report. 2. CIVIL AVIATION ACTIVITIES IN BOTSWANA At the time of the audit follow-up mission, civil aviation activities in Botswana included:

3 - 2 - a) number of technical staff employed by the organization at Headquarters 12 b) number of regional offices 1 c) number of technical staff employed at regional offices 4 d) number of active pilot licences 423 e) number of active flight crew licences other than pilot licences (flight engineer and flight navigator) N/A f) number of aviation training establishments 2 g) number of active licences other than flight crew licences 326 h) number of commercial air transport operators 18 i) number of air operator certificates (AOCs) issued 18 j) number of aircraft operations inspectors 5 k) number of aircraft registered in Botswana 182 l) number of currently valid Certificates of Airworthiness (C of A) issued 143 m) number of approved maintenance organizations (AMOs) 5 n) number of non-approved aircraft maintenance organizations N/A o) number of design organizations N/A p) number of aircraft manufacturing organizations N/A q) number of aircraft parts or equipment manufacturing organizations N/A r) number of aircraft type certificates issued N/A s) number of type certificates other than aircraft issued N/A t) number of aircraft airworthiness inspectors 8 3. EXECUTIVE SUMMARY 3.1 The DCA has made some progress in the area relating to the primary aviation legislation and civil aviation regulations. A new Civil Aviation (Amendment) Act of 1999 and the new Air Navigation Regulations (ANRs) of 2000 have been prepared and submitted to the Parliament for promulgation which is expected by June ICAO has been notified of all regulatory differences and all interim Flight Safety Notices have been published in the Aeronautical Information Publication (AIP). A Flight Safety Notice to require compliance with the provisions of Annexes 1, 6 and 8 has been issued as an interim measure pending promulgation of the new ANRs.

4 The DCA has complied with only one of the recommendations made during the audit relating to civil aviation organization. The DCA has issued a brief statement of policy on inspector training but has not developed a comprehensive training programme to specify detailed training requirements for all inspector positions. Government funding for retention, remuneration and training of technical staff continues to be a problem but may be improved by implementation of the semi-autonomous DCA planned for April Due to limited resources at this time, the DCA has not yet developed specific requirements for the approval of training schools. 3.3 Little progress has been made in the area of personnel licensing. The DCA has issued a Flight Safety Notice (FSN) to specify that private pilot licences and type ratings will be issued on the basis of the requirements specified in the current edition of Annex 1. All other licences issued by the State will only be issued on the basis of a foreign licence. Although more complete regulations will be specified in the new ANRs, some additional interim procedures are still required. Due to limited resources, the DCA has not yet developed specific requirements for the approval of training schools. Flight Safety Notice No has been reissued to require compliance with the medical fitness Standards of Annex 1 and to provide procedural advice to medical examiners. 3.4 Some progress has been made in the area relating to aircraft operations certification and supervision. The DCA has developed new draft ANRs which have been submitted to Parliament for promulgation. As an interim measure, the DCA has issued an addendum to Flight Safety Notice No. 001 Air Operator Certificates to require full compliance with all provisions of Annex 6, Part I and Doc The draft of the new ANRs will provide a comprehensive regulatory basis for the transport of dangerous goods by air, but no special training has been provided to the person responsible for dangerous goods. A schedule has been generated for the conduct of annual base inspections but, due to a lack of human resources, the DCA has not developed a comprehensive system for the surveillance of air operators. The State airline is in the process of re-issuing all operations and training manuals to incorporate amendment systems and to ensure compliance with State regulations. 3.5 Little progress has been made in the area of airworthiness. The DCA has yet to establish reliability programme requirements and inclusion of structural integrity programmes into the approved maintenance programme of operators. The requirement for operators to produce a minimum equipment list (MEL) from a master minimum equipment list (MMEL) has to be established and subsequently implemented. The development of a comprehensive procedure and subsequent amendment of the Airworthiness Inspector s Manual to include all airworthiness activities, type of inspection and checklists along with the development of a surveillance programme for both AOC holders and AMO s should be given priority. Furthermore, the DCA should assign a full-time technical staff to organize and manage the technical library and establish a system for the proper control, record and distribution of its continuous airworthiness documentation. 4. RESULTS OF THE AUDIT FOLLOW-UP MISSION 4.1 Primary aviation legislation and civil aviation regulations a) Action proposed by State. With respect to the recommendation on the need to review and amend the Act and the ANRs to ensure full compliance with related

5 - 4 - Annex SARPs, the DCA indicated that this will be completed by 31 December In the meantime, the DCA will issue, by 30 June 2000, a Flight Safety Notice to incorporate the provisions of Annexes 1, 6 and 8 as a temporary measure, pending the promulgation of the draft Act and ANRs. On 30 March 2000, the DCA indicated that it was in the process of implementing the proposed action plan and complete the implementation of this action by 30 April 2000 instead of 30 June b) Validation of action proposed. A new Civil Aviation (Amendment) Act of 1999 and the new ANRs of 2000 are in draft form. These have been submitted to the Parliament and are under legislative review. Promulgation is planned for 31 March ICAO has been notified of all regulatory differences and all interim Flight Safety Notices have been published in the AIP a) Action proposed by State. With respect to the recommendation on the need to amend the Act to address the responsibility and powers of the DCA and its Director, the DCA indicated that this will be completed by 31 December In the meantime, the DCA will issue, by 30 June 2000, a Flight Safety Notice to incorporate the provisions of Annexes 1, 6 and 8 as a temporary measure, pending the promulgation of the draft Act and ANRs. b) Validation of action proposed. The ICAO recommendation remains open until such time as the ANRs come into force. The DCA anticipates the promulgation of the ANRs by 31 March Organization of civil aviation a) Action proposed by State. With respect to the establishment of formal training policy and programme, the DCA indicated that a training policy, outlining the minimum initial, recurrent and upgrade training that an inspector should receive, will be established by 31 October 2000 and the Government will be requested to provide the necessary funds for training purposes by 15 September b) Validation of action proposed. The DCA has issued a single page statement of policy on inspector training but has not developed a comprehensive training programme to specify detailed training requirements for all inspector positions. Government funding for training continues to be a problem but may be improved by implementation of the semi-autonomous DCA planned for June The DCA anticipates that the ICAO recommendation will be complied with by August a) Action proposed by State. Concerning the difficulties of retaining experienced technical staff and providing adequate technical training to its staff, the DCA indicated that this issue will be addressed by the Ministry of Works, Transport and Communications and the recommendations are expected to be implemented by 31 December 2000.

6 - 5 - b) Validation of action proposed. Retention, remuneration and training of technical staff continue to be a serious problem. Funding for these issues may be improved by establishment of a semi-autonomous DCA scheduled for 30 April The ICAO recommendation remains open. Note. Subsequent to the audit follow-up mission, the DCA submitted a letter to ICAO, dated 27 March 2002, indicating that the cabinet approval for the transformation of the DCA into a parastatal Civil Aviation Authority has been received. The legislative process of enacting the Civil Aviation Authority Act, which would in turn repel the existing Civil Aviation Act, is in progress. The Civil Aviation Authority is scheduled to be established in April It is expected that a minimum period of three years would be required for the transformation process a) Action proposed by State. Concerning the need for DCA inspectors to be provided with appropriate credentials, the DCA indicated that the development of credentials is currently in progress and these will be issued to all inspectors by 30 June b) Validation of action proposed. Credentials have now been issued to all inspectors which allow unrestricted access to all aviation installations. The ICAO recommendation has been complied with. 4.3 Personnel licensing and training a) Action proposed by State. With respect to the recommendation of establishing the detailed conditions for the issuance of licences and ratings, the DCA indicated that a Flight Safety Notice specifying the detailed requirements for the issuance of a licence and ratings will be implemented by 31 October 2000 and included in Schedule 9 of the ANRs by 31 December The implementation date of the Flight Safety Notice was advanced to 30 April b) Validation of action proposed. The DCA issued in April 2000 Flight Safety Notice No Conditions to be met for the Issuance of Flight Crew Licences which specifies that private pilot licences and type ratings will be issued on the basis of the requirements specified in the current edition of Annex 1. All other licences issued in the State will only be issued on the basis of a foreign licence. More complete regulations will be specified in the new ANRs which are expected to be promulgated by March However, in the short term, Flight Safety Notices will be issued by June a) Action proposed by State. Concerning the need for the DCA to establish a procedure to ensure that foreign licences and ratings used as the basis for the issuance of the State s flight crew licences meet all the relevant requirements of ICAO Annex 1, the DCA indicated that it will, by 31 October 2000, establish procedures to ensure that applicants for validation or conversion of foreign licences meet all the relevant requirements of Annex 1. The DCA will also issue a Flight

7 - 6 - Safety Notice notifying any additional conditions which may be required for the conversion of most common foreign licences. b) Validation of action proposed. A Flight Safety Notice specifying additional conditions and procedures which will be required for the conversion of foreign licences will be issued by October The ICAO recommendation remains open a) Action proposed by State. Concerning the establishment of specific requirements and conditions for approving aviation training institutes and courses, the DCA indicated that, by 31 October 2000, it will develop the necessary requirements and conditions in line with ICAO guidance for the approval of aviation training institutes and courses. b) Validation of action proposed. Due to limited resources, the DCA has not yet developed specific requirements for the approval of training schools. This action item remains in progress with completion planned for June a) Action proposed by State. With respect to the need to review and amend Flight Safety Notice No concerning medical Standards, the DCA indicated that it will complete its review and amend it as necessary by 31 October The DCA also indicated that the designated medical examiners will be advised to use Doc 8984 as guidance for the implementation of the medical Standards contained in Chapter 6 of Annex 1. The implementation date initially indicated was advanced and the action was expected to be completed by 30 April b) Validation of action proposed. Flight Safety Notice No has been reissued to require compliance with the medical fitness Standards of Annex 1 and to advise medical examiners to use Doc 8984 as guidance for the implementation of the medical Standards of Annex 1, Chapter 6. The ICAO recommendation has been complied with. 4.4 Aircraft operations certification and supervision a) Action proposed by State. With respect to the need to review and amend the ANRs and update Flight Safety Notice No. 001 to ensure full compliance with Annex 6 requirements, the DCA indicated that the ANRs will be reviewed and amended by 31 December 2000 and Flight Safety Notice No. 001 would be updated by 30 April 2000 to fully comply with the requirements contained in Annex 6 SARPs and the guidance material contained in Doc b) Validation of action proposed. The DCA has developed new draft ANRs which have been submitted to Parliament for legislative review with promulgation expected by June In the interim, the DCA has issued an addendum to Flight Safety Notice No. 001 Air Operator Certificates to require full compliance with all provisions of Annex 6, Part I and Doc The ICAO recommendation remains

8 - 7 - open until such time as the ANRs come into force. The DCA anticipates the promulgation of the ANRs by March a) Action proposed by State. On the subject of the establishment of effective inspection and surveillance procedures and schedule, the DCA indicated that, by 1 April 2001, it will complete the development of procedures for the surveillance of operators and implement an inspection schedule based on the guidance provided in paragraph of Doc b) Validation of action proposed. The DCA has generated a schedule for the conduct of annual base inspections but has not developed a comprehensive system of surveillance for air operators due to a lack of manpower resources. The DCA anticipates that the ICAO recommendation will be complied with by April a) Action proposed by State. With respect to the recommendation on the amendment of the regulations relating to the transport of dangerous goods by air, the DCA indicated that the provisions of Annexes 6 and 18 and the Technical Instructions relating to the transport of dangerous goods by air will be incorporated into the ANRs by 31 December b) Validation of action proposed. The draft ANRs which have been submitted to Parliament provide a comprehensive regulatory basis for the transport of dangerous goods by air. Although one person has been appointed to be responsible for dangerous goods programmes, no special training has been provided. The DCA anticipates that the ICAO recommendation will be complied with by 30 August a) Action proposed by State. On the issue of ensuring that the training manuals presented by AOC holders contain details of requirements for initial, recurrent and type training for cabin crew, the DCA indicated that operators will be instructed to include such information in their training manuals, to be implemented by 31 October 2000, and that inspections will also be carried out to ensure compliance. 4.5 Airworthiness b) Validation of action proposed. The State airline is in the process of re-issuing all operations and training manuals to incorporate amendment systems and to ensure compliance with State regulations. The DCA indicated that the State airline should complete drafting the manuals and the review and approval by the DCA are now expected by June The ICAO recommendation remains open a) Action proposed by State. With respect to the need for the DCA to review its surveillance needs and consolidate all task instructions and checklists into an inspectors handbook, the DCA indicated that the existing inspectors handbook was being reviewed and checklists will be developed on the basis of guidance material contained in Doc The revised handbook and checklists are expected to be

9 - 8 - completed by 31 October The DCA also indicated that the inspectors indoctrination programme will be developed following the completion of the revised inspectors handbook to enable them to use it effectively. b) Validation of action proposed. The DCA has revised the Airworthiness Inspector s Manual. However, the manual needs to be further developed to include all airworthiness activities and checklists. The DCA anticipates that the ICAO recommendation will be complied with by October a) Action proposed by State. On the subject of maintaining a copy of the latest maintenance programme approvals in the technical library of the DCA and the assignment of a librarian to ensure proper maintenance and management of the library, the DCA indicated that the responsibility will be assigned to a staff member and all the necessary documents will be procured for the library by 31 October b) Validation of action proposed. Despite the fact that the DCA has delegated the task of organizing the technical library to one of the airworthiness inspectors as an additional duty, the library is still not organized and managed and no system has been established. Furthermore, not all technical publications are available for the type of aircraft registered in Botswana. The DCA anticipates that the ICAO recommendation will now be complied with by January a) Action proposed by State. With respect to the development of procedures for the issue of initial airworthiness certificates, the DCA indicated that it will develop such procedures on the basis of ICAO guidance, provide training to its airworthiness inspectors on the developed procedures and issue an Aeronautical Engineering Notice to the industry indicating the new requirements and procedures by 31 December b) Validation of action proposed. Preliminary procedures have been developed to issue initial airworthiness certificates. However, additional work is required to complete this project and implementation has not yet started. The DCA is currently issuing certificates of airworthiness without validating Type Certificates and procedures need to be developed. The DCA anticipates that this would be accomplished by October a) Action proposed by State. With respect to the development of procedures to notify operators that flight permits are not valid for use in foreign airspace except with the concurrence of the State(s) whose airspace is entered, the DCA indicated that an Aeronautical Engineering Notice will be issued to this effect by 30 June 2000 and will be included as part of the procedures and requirements for requesting a permit to fly into foreign airspace. b) Validation of action proposed. The DCA has issued Aeronautical Engineering Notice No. 35 in November 2000 on the issue of notifying operators on the use and

10 - 9 - limitation of the Botswana issued flight permits in the airspace of other Contracting States. The ICAO recommendation has been complied with a) Action proposed by State. On the subject of the need to develop guidelines and procedures for the issuance of export approvals and notifying operators of the limitations of approvals, the DCA indicated that guidance will be developed and incorporated into the inspectors handbook by 31 December An Aeronautical Engineering Notice will also be issued on export approvals by the same time. b) Validation of action proposed. The DCA has issued Aeronautical Engineering Notice No. 36 in November 2000 which adequately addresses export approvals. The ICAO recommendation has been complied with a) Action proposed by State. With respect to the development of an inspector work programme and formal checklists, the DCA indicated that such a programme and formal checklists will be developed by 31 December 2000 and included in the inspectors handbook. In addition, a computerized system will be developed using the existing software and new checklists will be developed to complement the existing ones which will also be revised and improved. b) Validation of action proposed. A preliminary surveillance plan has been developed; however, additional work is required to address all types of inspections and their frequencies. The DCA has indicated that the ICAO recommendation should be complied with by October a) Action proposed by State. Concerning the need to institute a system of review of maintenance arrangements for new carrier certification purposes and the need for the Airworthiness Section to be involved in the certification of operators, the DCA indicated that a review of maintenance arrangements for new carrier certification will be instituted per ICAO guidelines by 31 December 2000 and that it will review the existing inspection programmes to include maintenance issues. AOC inspections will also be included in the airworthiness inspection programme. b) Validation of action proposed. The DCA has created a procedure to certify an AMO; however, the DCA has not yet developed a procedure for the certification of air operators, nor the procedures for handling the evaluation of maintenance arrangements. The DCA anticipates that the ICAO recommendation will be complied with by October a) Action proposed by State. With respect to the recommendation of requiring operators to submit regular reliability programme reports, the DCA indicated that a reliability programme will be developed with the airline by 31 October The airline will then be required to report regularly to the DCA by 31 December 2000.

11 b) Validation of action proposed. The DCA has not yet developed requirements and procedures to govern maintenance reliability programmes. The DCA now anticipates that this will be carried out by October a) Action proposed by State. With respect to the recommendation of requiring operators to ensure that a structural integrity programme exists, where applicable, the DCA indicated that procedures for ensuring the existence of a structural integrity programme, as applicable, will be established by 31 December b) Validation of action proposed. The DCA has not yet developed requirements or procedures to ensure that a structural integrity programme is developed and included in an approved maintenance programme. The DCA now anticipates that the ICAO recommendation will be complied with by June a) Action proposed by State. With respect to the recommendation of requiring operators to submit a MEL, the DCA indicated that operators will be instructed to produce a MEL, by 31 December Procedures for the approval of a MEL will be developed and incorporated into the inspectors handbook by the same time. b) Validation of action proposed. A master minimum equipment list (MMEL) is still accepted as the operators MEL. The DCA has yet to develop requirements and procedures for operators to establish a MEL. Note. Subsequent to the audit follow-up mission, the DCA submitted a letter to ICAO, dated 27 March 2002, indicating that the DCA is now in the process of developing the requirements and procedures for a MEL and anticipates the ICAO recommendation to be complied with by October UPDATE ON DEPARTURES FROM ICAO SARPS During the audit follow-up mission, an updated list on the status of implementation and differences existing between the national regulations and Annexes 1, 6 and 8 SARPs and/or SARPs not implemented was not provided to the audit follow-up team. As such, Botswana is urged to conduct a thorough review of its national legislation and regulations and to notify ICAO of any differences as required under Article 38 of the Chicago Convention. 6. AUDIT FINDINGS AND DIFFERENCES DATABASE (AFDD) The general objective of the AFDD is to assist States in identifying the elements that need attention in the implementation of the proposed corrective action plan. The information is also intended to assist States in establishing a priority of actions to be taken to resolve safety concerns identified by the audits. The Appendix to this report contains a graphic representation of the lack of effective implementation of the critical elements of safety oversight (Doc 9734 refers) in Botswana and at a global level. The graphic representation of the State level depicts the situation during the initial audit and the situation at the time of

12 the audit follow-up mission. The graphic representation enables Botswana to prioritize the necessary corrective actions and to identify assistance requirements based on its personnel, technical and financial capabilities in consideration of its safety oversight obligations.

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