AUDIT SUMMARY REPORT OF THE DIRECTORATE GENERAL OF CIVIL AVIATION OF KUWAIT

ICAO Universal Safety Oversight Audit Programme AUDIT SUMMARY REPORT OF THE DIRECTORATE GENERAL OF CIVIL AVIATION OF KUWAIT (Kuwait, 22 to 30 October 2000) INTERNATIONAL CIVIL AVIATION ORGANIZATION

ICAO UNIVERSAL SAFETY OVERSIGHT AUDIT PROGRAMME Audit Summary Report on the Safety Oversight Audit Mission to Kuwait (Kuwait, 22 to 30 October 2000) 1. BACKGROUND 1.1 The Directorate General of Civil Aviation (DGCA) of Kuwait was initially assessed under the voluntary ICAO Safety Oversight Assessment Programme from 23 to 28 November 1996 by an ICAO assessment team. This audit was carried out from 22 to 30 October 2000 pursuant to Assembly Resolution A32-11 and in accordance with the updated Memorandum of Understanding (MOU) agreed on 16 February 2000 between Kuwait and ICAO. The objectives of this 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 1996 and to re-ascertain the safety oversight capability of the DGCA of Kuwait. The audit also aimed to ensure that Kuwait is in conformity with ICAO Standards and Recommended Practices (SARPs), as contained in Annexes 1, 6 and 8 to the Chicago Convention, associated guidance material and good aeronautical practices. 1.2 On 28 December 2000, Kuwait submitted an 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 contained in the audit interim report. The action plan and clarifications submitted were reviewed by the Safety Oversight Audit (SOA) Section and were found to be satisfactory. The action plan and comments were, as appropriate, taken into consideration in the preparation of this summary report. 2. CIVIL AVIATION ACTIVITIES IN KUWAIT At the time of the audit the civil aviation activities in Kuwait included: a) number of technical staff employed by the organization at Headquarters 18 Headquarters (Aviation Safety Department) b) number of active pilot licences 314 c) number of active flight crew licences other than pilot licences 15 d) number of active licences other than flight crew licences 448 e) number of commercial air transport operators 1 f) number of air operator certificates (AOCs) issued 1 g) number of aircraft operations inspectors 4 h) number of aircraft registered in Kuwait 23

- 2 - i) number of Certificates of Airworthiness issued 23 j) number of approved maintenance organizations (AMOs) in Kuwait 1 k) number of AMOs abroad 13 l) number of aircraft airworthiness inspectors 4 3. SUMMARY OF FINDINGS 3.1 General statement 3.1.1 Kuwait has established a regulatory framework which enables the implementation of the SARPs contained in Annexes 1, 6 and 8. Law No. 30 of 24 June 1960 on the issuance of Kuwaiti Civil Air Navigation Regulations is the primary aviation legislation and it addresses the major aspects of the supervision of aviation activities. In addition to the provisions of this law, all provisions of ICAO Annexes are considered legally binding. In addition, the Kuwait Civil Aviation Safety Regulations (KCASR), adopted in 1996, implement specific technical regulations. The DGCA has noted that the existing regulations do not cover certain SARPs and amended KCASR are expected to be enacted soon. 3.1.2 The Directorate General of Civil Aviation (DGCA) is an autonomous body, administratively attached to the Minister of Communications, and is headed by a President who is appointed by an Amiri Decree. The Aviation Safety Department (ASD) of the DGCA has been assigned the safety oversight tasks, functions and responsibilities to which Kuwait has committed under the Convention on International Civil Aviation. The ASD is adequately equipped and staffed and has adequate resources to undertake its safety oversight responsibility. Overall, the organizational system in place is comprehensive and satisfactory. 3.1.3 The DGCA has established regulations governing the issue and renewal of flight crew licences and for the certification of aviation maintenance technicians schools. However, these regulations have not been updated to reflect recent amendments to Annex 1. The system of licensing, approval and supervision is adequate, despite the fact that some procedures were missing. The Licensing Division does not have the required expertise to undertake the technical tasks related to licensing activities and these are conducted by other Divisions (Flight Operations, Airworthiness and the Air Navigation Department). There are no procedures established for the designation and control of medical examiners. 3.1.4 The KCASR contain the regulations implemented by the DGCA applicable to aircraft operations. The ASD has established a comprehensive system, which is satisfactorily documented, for the certification and supervision of the sole commercial air transport operator in Kuwait. Operations inspectors are highly qualified and experienced and are provided with comprehensive guidance and checklists for the conduct of their duties. The ASD has also established a training policy and structured training programme for operations inspectors. The DGCA acknowledges that the existing KCASR do not adequately address all of the provisions contained in Annex 6 and a revision of the KCASR is in progress and expected to be completed soon. 3.1.5 Kuwait has an effective Airworthiness Division which carries out its mandate in accordance with the KCASR, Kuwait Civil Aviation Safety Instructions (KCASI) and written guidance and procedures.

- 3 - The Airworthiness Division makes recommendations concerning the certification and continuing oversight of the national airline s maintenance arrangements and maintenance organization in addition to thirteen foreign maintenance organizations. The Airworthiness Division is adequately and appropriately staffed with trained and qualified personnel. The design and manufacturing codes of the FAA, JAA and BCAR were formally adopted at the time of the audit requiring that they be assessed for differences vis-à-vis the provisions of Annexes 6 and 8. 3.2 Primary aviation legislation and civil aviation regulations in Kuwait 3.2.1 Abstract of findings 3.2.1.1 The primary aviation legislation in Kuwait is Law No. 30 of 24 June 1960 on the issuance of Kuwaiti Civil Air Navigation Regulations ( Law No. 30 ). Law No. 30 was promulgated by an Amiri Decree, and contains all the basic legislation necessary to administer and control civil aviation activities in Kuwait. Article II designates to the President of the DGCA the responsibility for implementing the Decree and designates the DGCA as the competent authority in charge of functions relating to the control of civil aviation activities. Law No. 30 also contains provisions for the establishment of specific aviation regulations to address various aviation issues and to implement the provisions of ICAO Annexes 1, 6 and 8. It also empowers the DGCA to undertake actions to regulate and exercise supervision of civil aviation activities. 3.2.1.2 The supervision and enforcement provisions of Law No. 30 are contained in Parts VI and Part VIII. The DGCA may suspend any validation or other document it has granted pending the investigation of an offence. An authorized person from the DGCA has the right to prevent an aircraft from operating if the operation will be conducted in contravention to the regulations or if it appears that the operation may place persons or goods on board the aircraft at risk. The Act allows for inspection of an aircraft by an authorized person and provides for penalties for violations of the provisions of the law or any other regulation. 3.2.1.3 Kuwait ratified Article 83 bis of the Convention on International Civil Aviation by means of Amiri Decree 14/92 which recommended, inter alia, that the DGCA develop an appropriate framework to implement Article 83 bis. However, the DGCA has not yet developed regulations applicable to the oversight of operations conducted under Article 83 bis and allowing for the transfer and acceptance of responsibilities pertaining to Articles 12, 30, 31 and 32(a) of the Convention. 3.2.1.4 The Minister in charge of civil aviation may issue ministerial decisions under which Kuwait Civil Aviation Safety Regulations (KCASR) are issued, and by delegation from the Minister, the President of the DGCA may issue regulations. The existing KCASR were issued by the Minister of Communications through Ministerial Decision No. 18 dated 25 May 1996, which also delegates to the President of the DGCA the power to issue any amendment or revision to the regulations. The KCASR comprise fifteen parts and, although mainly based on ICAO Annex provisions for the licensing, certification and control of personnel, aircraft and organizations, they do not address all the SARPs contained in Annexes 1, 6 and 8. The DGCA has initiated a revision of the KCASR and a draft amendment was seen by the audit team. 3.2.1.5 Once a regulation is issued, the DGCA is responsible for its enforcement, according to the provisions of Law No. 30. To this effect, the KCASR describes the authority, responsibilities, policies, guidelines, procedures, objectives, and legal aspects of the DGCA s compliance and enforcement rules. 3.2.2 Corrective action proposed/implemented by Kuwait

- 4-3.2.2.1 With respect to Article 83 bis, the DGCA indicated that, by 1 January 2002, it will develop an appropriate regulatory framework under the new KCASR to allow for the oversight of operations conducted under Article 83 bis and for the transfer and acceptance of responsibilities. The DGCA will also establish procedures for its inspectorate staff to recognizes licences and certificates issued on this basis. 3.2.2.2 With respect to the recommendation that a system be established for ensuring that the KCASR reflect amendments made to ICAO SARPS, the DGCA indicated that a circular establishing such a system has already been issued by the President of the DGCA for the purpose of implementing this recommendation. 3.3 Civil aviation organization system in Kuwait 3.3.1 Abstract of findings 3.3.1.1 The civil aviation organization system in Kuwait comprises two independent entities, with separate levels of intervention and decision making responsibilities. High-level representatives of authorities concerned with civil aviation policy issues serve on the Supreme Council of Civil Aviation which was constituted by an Amiri Decree in 1963 to handle all policy matters related to the civil aviation sector. Decisions concerning the regulation of operators, airspace management, security and flight safety are the domain of the DGCA. Law No. 30 formally designates the DGCA as the authority in charge of aircraft registration and the surveillance of aircraft operations and licenced personnel. 3.3.1.2 The DGCA, headed by a President, is an autonomous entity attached to the Minister of Communication. The DGCA has always been administratively independent from the Ministry of Communications with its own budget. The President, the Director General and the four Deputy Directors General are appointed by an Amiri Decree. The DGCA is responsible for providing services and facilities for civil aviation and air transport. This includes the regularity, efficiency, security and safety of aircraft and passenger traffic in accordance with international commitments and the terms of conventions, agreements and protocols signed by Kuwait. The responsibilities undertaken by the DGCA include regulatory and supervisory functions, air navigation services, Kuwait airspace and airports. 3.3.1.3 The tasks and functions relating to the safety oversight of civil aviation activities in Kuwait are conducted by the ASD, organized under the Deputy Director General for Aviation Safety and Air Transport Affairs. The ASD comprises four divisions: Flight Operations, Airworthiness, Licensing, and Technical Research and Development. The ASD undertakes a wide range of activities, such as the licensing and supervision of civil aviation personnel and organizations, the registration and continued airworthiness of aircraft, the approval of specific operations such as ETOPS, precision approach procedures and minimums, and so on. The responsibility for the licensing and supervision of air traffic controllers is currently undertaken by the Air Navigation Department. 3.3.1.4 The ASD, headed by an experienced pilot, is appropriately staffed and has adequate resources (financial, personnel, buildings, libraries, documents, equipment, communications, networks and data bases) to undertake its responsibilities for the existing level of aviation activity. Remuneration is comparable to that offered by the industry, which allows the ASD to attract qualified and experienced technical inspectors in the different specialities. The recruitment process is under the control of the ASD.

- 5-3.3.1.5 During the audit and in line with the procedures established on the basis of the MOU signed between Kuwait and ICAO, the civil aviation organization in Kuwait was found to be comprehensive and satisfactory and no findings were identified which would require the development of a corrective action plan. 3.4 Personnel licensing and training Kuwait 3.4.1 Abstract of findings 3.4.1.1 The KCASR contain detailed regulations applicable to the training requirements for personnel licences, designation and training of instructors, and medical standards and certification. Regulations have recently been developed, based on Annex 1 requirements, which address the licensing of air traffic controllers; however, the medical standards in these regulations have yet to be customized to meet State requirements. The regulations cover all aspects of personnel licensing obligations except the requirements for certification of flight training schools and authorization of medical examiners. In addition, these regulations have not kept pace with the SARPs contained in Annex 1. 3.4.1.2 The Licensing Division of the ASD is in charge of all licensing responsibilities. The Licensing Division has a staff of three administrative persons who conduct all the non-technical functions related to licensing. The Licensing Division is not able to undertake technical tasks and relies on the Flight Operations and Airworthiness Divisions to conduct technical tasks in their respective area of responsibilities, such as training approvals and personnel licensing examinations. The ASD also designates qualified flight and simulator instructors and examiners to conduct flight and simulator training and also to conduct type rating checks, in addition to the examinations normally conducted by the ASD operations inspectors. 3.4.1.3 A qualified medical examiner is authorized to conduct and evaluate medical examinations of flight and cabin crew of the national airline (Kuwait Airways). The qualification records of the designated medical examiner revealed extensive experience in the practice of aviation medicine and continuous training and participation in relevant conferences. However, Kuwait has not established specific requirements for the designation of medical examiners including tasks designated, classes of medical assessments, issuance of waivers and/or evaluation of reports conducted by other medical examiners. 3.4.1.4 Licensing Division personnel use a procedures manual and forms to conduct some of their activities. The application forms are designed to provide guidance to both applicants and inspectors on the requirements to be fulfilled. However, Kuwait has not developed guidance and procedures for the validation of various types of licence, the issuance of Kuwait licences based on foreign licences, the issuance of licences based on military qualifications, and the certification of aviation training institutes. 3.4.1.5 The inspectors from the Flight Operations and Airworthiness Divisions are responsible for the supervision and control of licences issued by the DGCA. A computer database, which can be accessed by the various divisions of the DGCA and by Kuwait Airways, is used to monitor the validity of all licences and ratings issued, including the validity of medical fitness certificates. 3.4.1.6 Two training centres established at Kuwait Airways and various foreign training centres are used for training purposes in Kuwait. One training centre, located within the Operations Department of Kuwait Airways, conducts flight simulator and ground training for flight crew members while a second centre, located within the approved maintenance organization, provides approved training for maintenance

- 6 - engineers. Training of air traffic controllers is conducted at the Public Authority for Applied Education and Training in Kuwait, as well as at foreign training centres. 3.4.1.7 The DGCA operations inspectors have adopted a system of audits to approve and ensure the validity of simulators. The records indicated that simulators used by the national airline either within Kuwait or abroad are approved. Training programs are also approved, based on the Kuwait Airways standards described in their general operations manual. 3.4.2 Corrective action proposed/implemented by Kuwait 3.4.2.1 a) With respect to the recommendation that requirements and procedures be developed for the designation of medical examiners, along with a system to enable review of reports submitted by designated medical examiners, the DGCA indicated that regulations for the approval, appointment and continued training of medical examiners will be established by 1 January 2002. A system has now been established whereby all medical reports issued by DGCA approved examiners are forwarded to the licensing section for review. b) By letter dated 29 August 2001, the DGCA advised that an amendment to the KCSAR has now been issued which sets forth specific conditions and procedures for the designation of medical examiners, and a system has been developed whereby reports issued by medical examiners can be reviewed. In addition, the President of the DGCA has issued a decision addressing the medical examination of air traffic controllers, their technical tests and their licensing, in a way that is commensurate with the needs of civil aviation in the State of Kuwait. 3.4.2.2 a) With respect to the need to develop policies, requirements, procedures and guidance material on the issuance of licences based on foreign licences, validation of foreign licences and the acceptance of military qualifications for the issuance of civilian licences, the DGCA indicated that the new KCASR, to be implemented by 1 January 2002, will reflect the regulatory requirements for issuing Kuwait licences on the basis of foreign licences, as well as the validation of foreign licences. The DGCA does not issue licences based on military qualifications. Procedures for the validation of licences will be published in the AIP by 1 January 2002. b) By letter dated 29 August 2001, the DGCA advised that a guide has now been issued indicating the regulatory requirements for issuing Kuwait licences on the basis of foreign licences as well as the validation of foreign licences. 3.5 Aircraft operations certification and supervision in Kuwait 3.5.1 Abstract of findings 3.5.1.1 The regulations applicable to aircraft operations in Kuwait are contained in Law No. 30, the KCASR, Part 3 Certification and Operations: Air carriers and commercial operators of aircraft and Law No. 31 of 1987 on regulating the civil aviation market in Kuwait. The existing KCASR, applicable to aircraft operations in Kuwait, do not directly address all aspects of the SARPs contained in Annex 6 to the Convention on International Civil Aviation. However, in practice, the ASD uses the provisions of Annex 6 and its related manuals in addition to the existing regulations.

- 7-3.5.1.2 The responsibility of certification and supervision of commercial air transport operators is carried out by the ASD and mainly by the Operations Division. The latter has the responsibility for both certification and surveillance of aircraft operators. The Division also conducts the approvals of crew training programmes, the designation of flight crew and cabin crew instructors and the approval of flight simulators used for the flight crew type ratings and for recency checks. The flight operations inspectors are mostly involved in the surveillance and inspection of the national airline, which is the only certified operator in Kuwait. Route inspections are conducted on a regular basis, with an average of four route inspections per month. Ramp inspections are also conducted on a random basis. 3.5.1.3 For carrying out its functions, the ASD is staffed with four operations inspectors, including the Aviation Safety Director. All operations inspectors are ATPL licensed, approved instructors, authorized examiners and have vast managerial experience with the national carrier and the sole AOC holder in Kuwait. Their type ratings cover the range of fleet presently operated by the national carrier. In addition to these four operations inspectors, the Operations Division also incorporates a cabin safety inspector who has a background of cabin supervisor and cabin crew approved instructor. 3.5.1.4 For the recruitment of operations inspectors, the ASD has established a general requirement which also provides guidelines for their qualification and experience. The ASD has also established a training policy and structured training programmes for its operations inspectors. This training comprises technical aspects, administrative matters, auditing techniques and accident investigation as the inspectors may be called upon to take part in accident investigation. The four ASD operations inspectors have been recruited from the national airline management and are highly qualified. 3.5.1.5 In accordance with the provisions of Law No. 30, a prospective operator is required to obtain a prior agreement, granted by the DGCA, to carry out any air transport activity. The technical capabilities of the prospective operator are assessed by the Operations and Airworthiness Divisions. The third part of the KCASR contains the established process for the certification of the operator and the Operations Division has developed guidance and procedures for its technical staff. 3.5.1.6 The certification procedures of the ASD are based on the KCASR and ICAO guidance material, mainly Doc 8335. The operator s certification system is also based on the knowledge and experience of the highly qualified and experienced staff. Checklists and guidance developed by the ASD provide the technical experts with comprehensive guidance in the conduct of their duties. 3.5.1.7 The DGCA has developed a regulation establishing flight and duty time limitations for flight and cabin crew and the operator is required to include this regulation in the operations manual. The operator is also required to provide the DGCA with its operations manual and its amendments. A full set of national operator s operations manuals is available in the ASD library. The approval of the minimum equipment list (MEL) is done in the Flight Operations Division in coordination and cooperation with the Airworthiness Division. 3.5.1.8 The Flight Operations Division has established a comprehensive surveillance system of the national operator based on an established policy and surveillance tasks contained in the Regulatory Compliance Manual.

- 8-3.5.2 Corrective action proposed/implemented by Kuwait The DGCA indicated in its action plan that the new KCASR will be implemented by 1 January 2002 and will be in conformity with the SARPs contained in Annex 6. The DGCA has also indicated that it will inform ICAO of any differences and that significant differences will be published in the AIP by 1 July 2001. 3.6 Airworthiness of aircraft in Kuwait 3.6.1 Abstract of findings 3.6.1.1 The KCASR include regulations for the approval, surveillance and continued airworthiness monitoring of aircraft activities and the licensing of maintenance engineers in Kuwait. KCASR are supplemented by requirements and procedures contained in Kuwait Civil Airworthiness Instructions, Kuwait Airworthiness Notices and the Airworthiness Technical Manual. Kuwait Airworthiness Notices are issued to circulate information to all concerned with the airworthiness of Kuwait-registered aircraft. The notices may contain mandatory instructions in addition to general information and, in some cases, may supplement existing requirements or instructions. However, mandatory instructions requiring compliance are not identified as such. 3.6.1.2 The Airworthiness Division consists of a Head and a Deputy Head of Division and two additional inspectors. The Head of Division and one of the inspectors are avionics specialists and the remaining two are engine/airframe specialists. The Division has a technical support staff of two. The duties and responsibilities of the Division include: assisting with the registration of aircraft, certification and surveillance of operators jointly with the Operations Division; issuing and renewing Certificates of Airworthiness; monitoring continuing airworthiness of aircraft; issuing and renewing maintenance organization approval certificates; monitoring continuing surveillance of maintenance organizations; accepting and approving maintenance programmes; examining and accepting candidates for validation and issue of Kuwait s maintenance engineer licences; and accepting and approving MELs jointly with the Operations Division. 3.6.1.3 The Airworthiness Division is adequately staffed with sufficient qualified personnel to enable the management and implementation of safety oversight of airworthiness matters in Kuwait. It consists of the national carrier operating twenty-three aircraft and the supervision of thirteen foreign maintenance organizations. 3.6.1.4 The Airworthiness Division has a reporting line to the Aviation Safety Director who in turn reports to the Deputy Director General of the DGCA. Included in the Airworthiness Division s responsibilities is the mandate to carry out safety oversight of operator maintenance arrangements. Oversight is carried out in close cooperation with the Operations Division. The Airworthiness Division calls upon the Technical Research and Development Division for technical support with regard to engineering and research and development. 3.6.1.5 The airworthiness inspectors are adequately qualified and trained to perform their duties. They are authorized by the DGCA for right of inspection and carry an appropriate credential. The two administrative support staff provide typing, filing, amendment services and general administration support. Office accommodation, communications equipment and a computer are provided and adequate for the current

- 9 - workload. Airworthiness Division inspectors are designated to be co-opted onto an accident investigation team in the event of an accident or serious incident. However, none of the inspectors have attended a recognized accident investigation course. 3.6.1.6 The Technical Research and Development Division is staffed by six qualified engineers and one assistant. The functions and responsibilities of the Division are to receive, evaluate and process technical data in support of AD compliance, modifications, occurrence reports, maintenance programmes, MELs, reliability programmes, etc. The data output from the Division is used by airworthiness inspectors when carrying out their certifications, inspections and audits. All required procedures appear in the Airworthiness Division manuals. 3.6.1.7 There is a well-equipped library available which contains technical manuals, design information, technical data, regulatory documents, microfilms, data CDs, etc. The library is well organized and secured. Inspectors are selected from the industry and trained and qualified to a high standard in accordance with a comprehensive training programme. Inspector training records are sampled and satisfactory progression was seen, from induction training to regulatory training to type training and recurrent training. 3.6.1.8 Air operator certification and maintenance organization certification are carried out in accordance with requirements and procedures contained in the KCASR and Kuwait Civil Airworthiness Instructions (KCASI). The certification process meets the criteria of ICAO guidance material. 3.6.1.9 Operator surveillance, continued airworthiness and maintenance organization supervision is conducted by planned audits, inspections, ramp audits and unannounced inspections. C of As, AOCs and AMO certificates are renewed annually, subject to satisfactory audits. Inspector guidance for operator and maintenance organization surveillance and certificate renewals is found in the Airworthiness Technical Manual which is Kuwait s equivalent of an Airworthiness Inspector s Handbook. 3.6.1.10 Operator and maintenance organization files are held by the Airworthiness Division. The files are comprehensive and include records of audits, findings and follow-up correspondence. 3.6.1.11 Design and manufacturing codes had been formally adopted by the State (FAR, JAR and BCAR). 3.6.1.12 The Technical Research and Development Division receives, prepares and issues technical data which is used to support airworthiness inspectors with their recommendations, validations, C of A inspections, MEL approvals, maintenance programme approvals, AD compliance reviews, etc. It was sometimes not clear from the files of the Technical and Research Development Division or from those of the Airworthiness Division if a function or review had been made, by whom it had been completed and when the information had been presented to the airworthiness inspector. 3.6.1.13 There are no aircraft design or manufacturing activities in the State. However, the Technical Research and Development Division is directly under the Aviation Safety Director. The engineers in the Technical Research and Development Division are not inspectors and therefore are not authorized to certify documents or make recommendations.

- 10-3.6.2 Corrective action proposed/implemented by Kuwait 3.6.2.1 With respect to the recommendation that the DGCA ensure that mandatory instructions are clearly identified as requiring compliance when included in Kuwait Airworthiness Notices, the DGCA indicated that in order to implement this recommendation holders of Kuwait Airworthiness Notices were clearly advised of the regulatory status of the Notices as well as the mandatory status of particular Airworthiness Notices. 3.6.2.2 a) Regarding the need for airworthiness inspectors assigned to accident investigation to receive suitable training, the DGCA indicated that the Aviation Safety Director has scheduled an airworthiness inspector to attend an accident investigation training course in May 2001 and the remaining inspectors will attend in September 2001. b) By letter dated 29 August 2001, the DGCA advised that two airworthiness inspectors completed a certified accident investigation training course in May/June 2001. 3.6.2.3 With respect to the recommendation that the recently adopted design and manufacturing codes be reviewed and amended to ensure that they are in accordance with ICAO SARPS, the DGCA indicated that it accepts the codes issued by the design and manufacturing states (eg., FAA, JAA, BCARs) and takes into consideration the differences with SARPS contained in Annexes 6 and 8 as filed by those states with ICAO. 3.6.2.4 With respect to the recommendation that the Technical Research and Development Division provide a summary document for any technical function undertaken for another division, the DGCA indicated that this has been implemented. Summary documents coordinating technical functions are issued which include details and analysis of the scope of the functions performed, the individual who carried out the function, his signature, completion date, and the date the document was presented to the concerned division. 4. COMMENTS As indicated above, Kuwait submitted an action plan on 28 December 2000, addressing all the findings and recommendations that were forwarded, including comments and feedback on the interim report sent on 6 December 2000. The corrective action plan submitted was reviewed and considered satisfactory. Kuwait has already implemented a number of the recommendations made by the ICAO audit team, with the balance to be implemented by January 2002. The DGCA is encouraged to keep ICAO regularly informed with regard to the implementation of the proposed action plan and the progress made in accordance with the schedule established.

- 11-5. STATUS OF IMPLEMENTATION AND DIFFERENCES FROM THE ICAO SARPs Although Kuwait was provided with and completed a pre-audit questionnaire to assist it in identifying differences between its national regulations and ICAO SARPs and/or SARPs not implemented, a list of such differences was not submitted to the audit team. Kuwait 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. END