SUMMARY REPORT ON THE SAFETY OVERSIGHT AUDIT FOLLOW-UP OF THE NATIONAL CIVIL AVIATION AGENCY OF ITALY

Transcription

1 ICAO Universal Safety Oversight Audit Programme SUMMARY REPORT ON THE SAFETY OVERSIGHT AUDIT FOLLOW-UP OF THE NATIONAL CIVIL AVIATION AGENCY OF ITALY (Rome, 30 to 31 May 2002) International Civil Aviation Organization

2 ICAO UNIVERSAL SAFETY OVERSIGHT AUDIT PROGRAMME Summary Report on the Safety Oversight Audit Follow-up of the National Civil Aviation Agency of Italy (Rome, 30 to 31 May 2002) 1. INTRODUCTION 1.1 Background The National Civil Aviation Agency (Ente Nazionale per l Aviazione Civile ENAC) of Italy was audited from 19 to 30 June 2000 by an ICAO safety oversight audit team in accordance with the Memorandum of Understanding (MOU) agreed to on 7 November 1999 between Italy and ICAO. The audit was carried out pursuant to Assembly Resolution A32-11, with the objective of ascertaining the safety oversight capability of ENAC and to ensure that it was 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 1 September 2000, Italy submitted a corrective action plan addressing all the findings and recommendations contained in the audit interim report. The action plan submitted was reviewed by the Safety Oversight Audit (SOA) Section and was found to be satisfactory. On 23 October 2000, ICAO received further clarifications from Italy and the action plan and these clarifications 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 19/1-00/99 in November Objectives and activities of the audit follow-up mission The 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 Italy through a non-confidential summary report. 2. CIVIL AVIATION ACTIVITIES IN ITALY At the time of the audit follow-up mission, civil aviation activities in Italy included: a) number of technical staff employed by the organization at Headquarters 70 b) number of regional offices 31 c) number of technical staff employed at regional offices 89 d) number of active pilot licences

3 - 2 - e) number of active flight crew licences other than pilot licences (flight engineer and flight navigator) 164 f) number of aviation training establishments 158 g) number of active licences other than flight crew licences h) number of commercial air transport operators 114 i) number of air operator certificates (AOCs) issued 109 j) number of aircraft operations inspectors 34 k) number of aircraft registered in Italy l) number of currently valid certificates of airworthiness issued m) number of approved maintenance organizations (AMOs) 273 n) number of non-approved aircraft maintenance organizations 0 o) number of design organizations 18 p) number of aircraft manufacturing organizations 9 q) number of aircraft parts or equipment manufacturing organizations 30 r) number of aircraft type certificates issued 84 s) number of type certificates other than aircraft issued 19 t) number of aircraft airworthiness inspectors EXECUTIVE SUMMARY 3.1 In the area of primary aviation legislation and civil aviation regulations, Italy has established a system to verify compliance of Joint Aviation Requirements (JARs) with ICAO SARPs before their introduction into the national legal framework; however, ENAC has not yet established a procedure to address amendments to ICAO Annexes. Agreements signed by Italy with other Contracting States under the provisions of Article 83 bis of the Chicago Convention are now filed with ICAO. ENAC is still in the process of adding a formal provision in the Air Navigation Code for the empowerment of inspectors and providing them with appropriate credentials. 3.2 With regard to organizational structure, the integration of the former Direzione Generale dell Aviazione Civile (DGAC), the Registro Aeronautico Italiano (RAI) and the Ente Nazionale Gente dell Aria (ENGA) into ENAC has been completed since the ICAO audit of Due to its status of public establishment, ENAC is now able to offer conditions of employment similar to those proposed by the private sector. ENAC has been able to recruit additional technical staff in the last year and expects to hire more in

4 - 3 - the near future. Issues still pending are the formalization of training policies and programmes and the development of a specific list of staff duties and responsibilities for each safety-related process. 3.3 In the area relating to personnel licensing and training, ENAC has established an Aeronautical Licences Service since the ICAO audit of This new division is adequately staffed with seven experienced pilot examiners in addition to the possibility of using the twenty-four pilot examiners from the Flight Operations Service, which allows for ENAC to carry out all professional pilot examinations. An extensive training and equipment programme, including Intranet and Internet connections of all personnel involved in the licensing process, has been carried out. However, the formal coordination and control of licensing tasks performed by the regional offices is not yet finalized. The system currently used in conducting medical fitness assessments of licence holders and applicants is not under the authority of ENAC, and no system has been established yet to allow ENAC to designate medical examiners. A legislative measure is under preparation in this regard. 3.4 On the subject of aircraft operations, ENAC has established an efficient system for the certification of air operators based on JAR-OPS 1 methodology. Additional operations inspectors have been recruited and all Italian air operators have been certified and granted with an AOC. However, current Italian regulations do not specify the limits applicable to flight time, duty time and rest periods for cabin crew and do not require all operators to establish an accident prevention and flight safety programme. These regulations have been drafted but have not yet been promulgated. 3.5 Progress in the field of airworthiness has been significant since the ICAO audit of Documents such as operative procedures and circulars have been developed to address most of the deficiencies identified. Procedures have been established to cover ferry flights, the issuance of airworthiness directives (ADs), Maintenance Review Board (MRB) activities, and the supervision of foreign non-jar-145 maintenance subcontractors has been enhanced. Issues still pending are the establishment of a formal mandatory reporting system and the improvement of the technical library provided to the airworthiness staff at ENAC Headquarters in Rome and in regional offices. 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 verification of the compliance of JAR amendments with the provisions of ICAO Annexes, ENAC indicated that it will sponsor an amendment to the new Joint Aviation Authorities (JAA) regulation JAR- 11 concerning the rule-making process to introduce a formal step for the verification of compliance to ICAO Annexes. An ENAC internal procedure will also be developed by 31 October 2000 to ensure that an evaluation of differences with ICAO Annexes will be carried out. b) Validation of action proposed. In parallel to JAR-11 which is not yet part of Italy s framework, ENAC has developed internal procedure P.O. GEN-01 dated 14 May However, there is no formal procedure for implementing amendments to ICAO Annexes. The ICAO recommendation remains open.

5 - 4 - Note. Subsequent to the audit follow-up mission, ENAC submitted an update on 22 August 2002 indicating that operative procedure P.O. GEN-01 Revision 1, containing provisions for implementation of amendments to ICAO Annexes, has been issued on 24 July a) Action proposed by State. Concerning the empowerment of airworthiness and operations inspectors, ENAC indicated that a proposal to the Ministry of Transport will be developed by 31 October 2000 to review the Air Navigation Code in order to expand the empowerment of ENAC to have unrestricted access to organizations, personnel, documentation and records for inspection purposes. A badge specifying the credential will be given to all inspectors by 30 June (Note.- Article 768 of the Air Navigation Code empowers ENAC to perform inspections and audits on civil registered aircraft.) b) Validation of action proposed. A modification to the Air Navigation Code was drafted by ENAC in April 2001 to formally expand the empowerment of its inspectors for unrestricted access to aviation facilities, organizations, personnel, documentation and records. However, this provision has not yet been promulgated. In the interim, ENAC intends to provide inspectors with credentials, based on a transitory internal decision, before the end of July The ICAO recommendation remains open. Note. Subsequent to the audit follow-up mission, ENAC submitted an update on 22 August 2002 indicating that the project for issuing ENAC badges with inspection credentials to all personnel has been finalized on 25 July The target date for the issuance of the badges is 31 December a) Action proposed by State. With regard to the notification to ICAO of any new agreement entered into pursuant to Article 83 bis of the Chicago Convention, ENAC will develop a new procedure by 31 March Pending the issuance of the new procedure, responsibility will be given to the Maintenance and Production Department to notify ICAO of any relevant agreement by 15 September b) Validation of action proposed. A Policy Letter, later emphasized in Operative Procedure ASV-08, establishes the procedures to follow for the signature of agreements with other Contracting States under Article 83 bis of the Chicago Convention. The procedures highlight the necessity to notify ICAO of these agreements. The ICAO recommendation has been complied with. 4.2 Organization of civil aviation a) Action proposed by State. With respect to the integration of the former DGAC, RAI and ENGA into one organization, ENAC indicated that the new organizational structure for a fully integrated safety oversight system is expected to be approved by 30 September 2000 along with a document with the description of the functions and tasks of the post holders by 31 March 2001.

6 - 5 - b) Validation of action proposed. The integration of the former DGAC, RAI and ENGA into ENAC has been formally established by a decision of ENAC s board in December 2000 and became effective on 2 January A document entitled Regolamento dell Organizzazione e del Personale contains ENAC s organizational chart and outlines the functions of each of its departments. However, a document establishing the functions, responsibilities and empowerment of staff members is still in progress. The ICAO recommendation remains open. Note. Subsequent to the audit follow-up mission, ENAC submitted an update on 22 August 2002 indicating that the review of tasks and responsibilities for each safety-related process has been completed by 28 July A formal ENAC Organization Manual is expected to be issued by the end of a) Action proposed by State. With respect to the development of a formal inspector s handbook for the use and guidance of personnel licensing, airworthiness and operations inspectors, ENAC indicated that a formal inspector s handbook will be developed and published by 31 December 2001 and, in the meantime, ENAC will issue a policy document defining guidelines for the inspection and surveillance duties by 31 October b) Validation of action proposed. A Manual of Procedures for Surveillance of Flight Safety has been developed and contains ENAC s policy on the establishment of guidance and procedures for technical staff. This document also contains the references of all procedural documents to be used by ENAC s personnel. The ICAO recommendation has been complied with a) Action proposed by State. With respect to the recommendation for a specialized training programme for inspectors, ENAC indicated that a working group would be established by 15 September 2000 to identify training requirements, and a written policy regarding initial and recurrent training for flight and ground inspectors will be developed by 15 December The training programme implementation is estimated to begin on 15 March b) Validation of action proposed. A working group has been established within ENAC to assess the training necessary for technical staff. In February 2001, this group submitted a document outlining the training requirements. A training policy and a formal training programme are still under development. ENAC expects to comply with the ICAO recommendation by the end of a) Action proposed by State. Concerning the recommendation to review the resources allocation policy in order to enable ENAC to recruit, train and retain qualified personnel, ENAC indicated that a re-definition of the workforce and the distribution of the inspectors as well as an increase in technical personnel will be carried out by 15 October The recruitment policy, conditions of services and salaries of all personnel will be reviewed taking into account the new ENAC labour contract. Estimated implementation date is 15 October 2000.

7 - 6 - b) Validation of action proposed. Due to its status of public establishment, ENAC is no longer the subject of some of the constraints imposed on the civil service in Italy. The level of salaries offered by ENAC is competitive with the conditions of employment proposed by the private sector. ENAC has been able to recruit thirteen additional technical staff in the last year and twenty-five more are scheduled for The ICAO recommendation has been complied with. 4.3 Personnel licensing and training a) Action proposed by State. With respect to the recommendation that the Personnel Licensing Department establish and maintain a technical library, ENAC indicated that the technical library will be revised, documents updated and made available to all staff, and an internal procedure for the management of the documentation will be issued by 30 September b) Validation of action proposed. The Aeronautical Licences Service has established a new library which contains licensing regulations, procedures and references published by ICAO and JAA, as well as Italian references. The ICAO recommendation has been complied with a) Action proposed by State. On the issue of restructuring the Personnel Licensing Department and establishing formal authority over licensing activities, ENAC indicated that a project for its reorganization will be completed by 31 October 2000, including a directive specifying the tasks and responsibilities of the assigned technical and clerical staff by 31 December The corresponding resources needed for the implementation of the new system will be allocated by 31 December b) Validation of action proposed. With the establishment of ENAC, an Aeronautical Licences Service has been established. Internal Order No. 4 issued on 7 December 2001 specifies tasks and responsibilities of licensing personnel. This service is adequately staffed, and an extensive training and equipment programme, including Intranet and Internet connections for all personnel involved in licensing processes, has been implemented. However, the formal coordination and control of licensing tasks performed by the regional offices is not yet finalized. ENAC expects to comply with the ICAO recommendation by the end of December a) Action proposed by State. With respect to obtaining additional pilot expertise, ENAC indicated that a decision has been taken to add pilot expertise to the Personnel Licensing Department, allowing the office to be in full control of the approval process of training syllabi and the practical examinations required for the issuance of licences, and it is expected to be implemented by 30 September b) Validation of action proposed. Seven experienced pilot examiners have been recruited since the ICAO audit of The twenty-four flight inspectors of ENAC s Flight Operation Service also are available to carry out practical

8 - 7 - examinations for professional pilots. The ICAO recommendation has been complied with a) Action proposed by State. On the issue of providing the Personnel Licensing Department with adequate equipment and resources, ENAC indicated that hardware acquisition will be completed by 31 December Specific software development will be achieved by 31 March 2001 and basic computer training for personnel will be implemented by 1 October b) Validation of action proposed. With the establishment of the Aeronautical Licences Service within ENAC, an ambitious programme for the provision of relevant computer equipment to all staff has been launched by ENAC. Personnel involved in licensing activities, including those in regional offices, have been provided with personal computers with Intranet and Internet connections and specific software allowing for the computerized preparation of licences. The ICAO recommendation has been complied with a) Action proposed by State. With respect to the addition of adequate medical expertise allowing the Personnel Licensing Department to be directly involved in the designation of medical examiners and the evaluation of medical reports, ENAC indicated that a Medical Department will be added to the ENAC structure, with a direct link to the Personnel Licensing Department for matters regarding the designation of medical examiners and the evaluation of medical reports, by 30 September b) Validation of action proposed. The system currently used in conducting medical fitness assessments of licence holders and applicants is not placed under the authority of ENAC. This system is under the responsibility of other Government departments, and ENAC has not designated medical examiners to conduct assessments of the fitness of applicants for licences and ratings. ENAC has recruited a medical adviser and now has the capability to evaluate medical assessment reports but has not yet formally established a system for the supervision and control of medical examiners and the evaluation of medical reports. ENAC is presently coordinating with the Government for the implementation of such a system. The ICAO recommendation remains open. Note. Subsequent to the audit follow-up mission, ENAC submitted an update on 22 August 2002 indicating that ENAC has established an Aeronautical Medicine Service in its organization with a full-time medical director and some medical advisers and now has the capability to evaluate medical assessment reports but has not yet been formally empowered to supervise and control medical examiners and evaluate medical reports. A new decree is currently in approval phase a) Action proposed by State. On the issue of the supervision, monitoring and control of all licensing functions performed by ENAC, the action plan indicated that ENAC will develop internal procedures for the performance of the monitoring functions.

9 - 8 - The corresponding resources needed for the implementation of the new system will be allocated by 31 December b) Validation of action proposed. Licensing procedures have been established by ENAC and allow for the control and supervision of licensing functions. However, the development of coordination mechanisms with regional offices is still in progress. ENAC expects to comply with the ICAO recommendation by the end of a) Action proposed by State. Concerning the recommendation on the establishment of a system to supervise and control the delivery of flight and practical tests performed by designated examiners, ENAC indicated that the system will be implemented and the corresponding resources allocated by 31 December b) Validation of action proposed. ENAC is currently carrying out all professional pilot theoretical and practical examinations using newly recruited examiners and Operation Division s pilots. Thirty-one experienced and current pilot examiners cover the entire scope of licensing activities. The ICAO recommendation has been complied with a) Action proposed by State. With respect to the need to review the format of the licences issued and provide translation of the required elements into one of the ICAO languages, ENAC indicated that the format of the personnel licences will be adopted with the implementation of JAR-FCL on 1 January b) Validation of action proposed. New licences are being issued by ENAC. These licences comply with the physical specifications of Annex 1 and, in particular, contain the necessary items in both the Italian and English languages. The ICAO recommendation has been complied with a) Action proposed by State. With respect to the need to allocate sufficient resources and facilities to establish a personnel licensing filing system, ENAC indicated that the re-organization of the Personnel Licensing Department will encompass a review of the archives and filing system by 31 December 2000 and its implementation, including an integrated databank, will be achieved by 30 June b) Validation of action proposed. ENAC has initiated a project aimed at the computerization of the personnel licensing filing system. However, this project is still in progress. ENAC expects to comply with the ICAO recommendation by 30 June Aircraft operations certification and supervision a) Action proposed by State. Concerning the recommendation that ENAC complete, as soon as possible, the certification process of all commercial air transport operators

10 - 9 - in order to issue AOCs in accordance with the provisions of Annex 6 and the National Aviation Regulations (NARs), ENAC indicated that its Safety Coordination Committee will develop a new plan by 30 September 2000 in order to complete the issuance of AOCs to all operators involved in international commercial air transport by 31 December ENAC also indicated that, as an emergency action, it is in the process of recruiting ten additional flight inspectors to be involved in this certification process after appropriate training has been given. b) Validation of action proposed. ENAC has established an efficient system for the certification of air operators based on JAR-OPS 1 methodology. Additional operations inspectors have been recruited to carry out the relevant inspections. All Italian air operators have been certified and granted with an AOC. The ICAO recommendation has been complied with a) Action proposed by State. With respect to the development and promulgation of flight and duty time limitation regulations for cabin crew, ENAC indicated that it is awaiting the issuance of the relevant European Union (EU) regulation with expected implementation by 31 December b) Validation of action proposed. A regulation specifying the limits to flight time, duty time periods and rest periods for cabin crew has been drafted and is still in a consultation process with operators, flight crew and cabin crew representatives. The ICAO recommendation remains open. Note. Subsequent to the audit follow-up mission, ENAC submitted an update on 22 August 2002 indicating that a new draft regulation on flight and duty time limitations has been produced on 26 July Formal approval is expected by the end of a) Action proposed by State. Concerning the recommendation on the lack of national regulations requiring all commercial air transport operators to establish and maintain an accident prevention and flight safety programme, ENAC indicated that it would develop a national regulation and interpretative material, taking into account JAR- OPS requirements and the provisions of Annex 6, by 31 October b) Validation of action proposed. Italian regulations still do not require operators of aircraft under kg and twenty passengers to establish an accident prevention and flight safety programme. With the full implementation of JAR-OPS 1, ENAC expects to comply with the ICAO recommendation by 30 September a) Action proposed by State. With respect to the recommendation on the need to establish a policy and adequate procedures ensuring that sufficient technical coordination exists between airworthiness and operations inspectors, on aspects such as ETOPS, RVSM, CAT II and III and MEL, ENAC indicated that under the Regulation Project, a high priority will be given to the action regarding the

11 development of circulars and procedures for special approval with expected implementation by 31 December b) Validation of action proposed. A clear policy to ensure the technical coordination between the Operations and Airworthiness Divisions in the operator approval processes is now clearly established in each relevant specific circular. This coordination is ensured through the constitution of an approval team using common procedures and checklists. The ICAO recommendation has been complied with a) Action proposed by State. With respect to the need to develop and promulgate national regulations on the transport of dangerous goods by air, ENAC indicated that a working group has been set up for establishing the regulatory framework. Training courses for inspectors have been planned in the ENAC training programme. ENAC also indicated that an air operator recurrent inspection programme would be implemented by 31 October b) Validation of action proposed. A new regulation dealing with the transport of dangerous goods by air has been drafted and is expected to be issued by the end of June The approval of air operator manuals and procedures is carried out by two inspectors within the Operations Division. A training programme for ground safety airport inspectors has been prepared and scheduled for the end of ENAC expects to comply with the ICAO recommendation by the end of December Airworthiness of aircraft a) Action proposed by State. With respect to the recommendation on the development of a circular on ferry flights permits, to include movement of aircraft which are not airworthy but need to be flown for maintenance, ENAC indicated that the circular will be promulgated by 31 December b) Validation of action proposed. Technical Regulation Chapter 31E-3 provides for special flight authorizations to be valid only within Italian airspace and requires validation by foreign authorities. Circular NAV-64 contains the procedures to be applied for their issuance. The ICAO recommendation has been complied with a) Action proposed by State. Concerning the development of a written procedure for the exchange of mandatory continuing airworthiness information with the State of Design and the State of Manufacture, ENAC indicated that a new circular will be issued on 31 December b) Validation of action proposed. Operative Procedure ASV-04 has been developed to give guidance on the issuance or adoption of airworthiness directives (ADs). It contains a provision for the exchange of systematic information of the State of

12 Design in case of issuance by ENAC of ADs applicable to aircraft designed out of Italy. The ICAO recommendation has been complied with a) Action proposed by State. With respect to the requirement to establish an effective system to monitor information on aircraft faults, malfunctions and defects reporting, ENAC indicated that a new circular concerning a computerized system for collecting and analysing faults and malfunctions data will be issued by 31 December ENAC s databank will be compatible with the databank on malfunctions adopted by the main Italian air operators. b) Validation of action proposed. Technical Regulation 30F-1 provides for the mandatory reporting by operators or maintenance organizations of accidents and incidents. However, this regulation does not establish that faults, malfunctions and defects have to be reported, and no formal organized system has been developed by Italy in that respect. ENAC expects to comply with the ICAO recommendation by the end of a) Action proposed by State. With respect to the recommendation on the need to improve the airworthiness technical library to include all relevant documents from design organizations, ENAC indicated that a working group has been established to identify its documentation needs and will acquire the necessary documentation by 31 March b) Validation of action proposed. A working group has been established within ENAC to review the necessary procurement of manufacturers documentation for the technical staff involved in airworthiness activities. This group has proposed the purchase of the relevant documentation through a CD-ROM subscription. However, the adoption of the corresponding budget is still pending. ENAC expects to comply with the ICAO recommendation by the end of a) Action proposed by State. With respect to the need for a written policy to enhance ENAC s safety oversight capability for proper control and supervision of non-jar-145 maintenance subcontractors, ENAC indicated that a procedure for the qualification of foreign personnel, including inspection by ENAC inspectors, will be developed by 31 October b) Validation of action proposed. A Policy Letter issued on 27 November 2000 establishes the requirement, policy and procedures for the continuing surveillance of non-jar-145 maintenance subcontractors. Inspection programmes are prepared by ENAC regional offices. The ICAO recommendation has been complied with a) Action proposed by State. With respect to the need to establish a procedure to ensure coordination between the Type Certification Department and the Maintenance Production Department regarding the Maintenance Review Board process, ENAC indicated that a new procedure will be developed by 31 October 2000.

13 b) Validation of action proposed. On 30 October 2000, Appendix 30 was introduced into the Certification and Validation Handbook to outline internal procedures for the establishment of the Maintenance Review Board. These procedures cover, in particular, the participation of staff from the Type Certification Department in the Maintenance Review Board and their coordination with staff from the Maintenance and Production Department. The ICAO recommendation has been complied with. 5. 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 provided to the audit follow-up team. The differences provided will be included in the relevant Annex supplement in line with Article 17 of the MOU signed between Italy and ICAO and in accordance with 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 Italy 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 the audit follow-up mission. The graphic representation will enable Italy 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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