ICAO Universal Safety Oversight Audit Programme AUDIT SUMMARY REPORT OF THE CIVIL AVIATION AUTHORITY OF SINGAPORE (Singapore, 11 to 19 September 2000) INTERNATIONAL CIVIL AVIATION ORGANIZATION
ICAO UNIVERSAL SAFETY OVERSIGHT AUDIT PROGRAMME Audit Summary Report on the Safety Oversight Audit Mission to Singapore (Singapore, 11 to 19 September 2000) 1. BACKGROUND 1.1 The Civil Aviation Authority of Singapore (CAAS) was audited from 11 to 19 September 2000 by an ICAO safety oversight audit team in accordance with the Memorandum of Understanding (MOU) agreed on 25 May 2000 between Singapore and ICAO. The audit was carried out pursuant to Assembly Resolution A32-11, with the objective of ascertaining the safety oversight capability of the CAAS and to ensure that it is in conformity with ICAO Standards and Recommended Practices (SARPs), as contained in Annexes 1, 6 and 8 to the Chicago Convention and related provisions in other Annexes, guidance material and relevant safety-related practices in general use in the aviation industry as referred to in such material. 1.2 On 25 November 2000, Singapore forwarded an action plan along with comments and clarifications on the contents of the audit interim report. The comments and clarifications were reviewed by the Safety Oversight Audit (SOA) Section and further discussions were held with a representative of the CAAS at ICAO headquarters on 10 January 2001. Additional information and evidence provided by the CAAS was reviewed and an updated interim report was prepared to enable the CAAS to develop its action plan. Accordingly, on 5 April 2001, Singapore submitted further comments and clarifications including a revised action plan, all of which have been taken into consideration in the preparation of the final and summary reports. 2. CIVIL AVIATION ACTIVITIES IN SINGAPORE At the time of the audit, the civil aviation activities in Singapore included: a) number of technical staff employed by the organization at Headquarters 26 b) number of active pilot licences 1 793 c) number of active flight crew licences other than pilot licences 1 942 d) number of active licences other than flight crew licences 1 546 e) number of commercial air transport operators 3 f) number of air operator certificates (AOCs) issued 3 g) number of aircraft operations inspectors 6 h) number of aircraft registered in Singapore 135 i) number of Certificates of Airworthiness issued 135
- 2 - j) number of approved maintenance organizations (AMOs) 84 located in Singapore 65 located in other States 19 k) number of aircraft parts or equipment manufacturing organizations 4 l) number of aircraft airworthiness inspectors 16 3. SUMMARY OF FINDINGS 3.1 General statement 3.1.1 The Air Navigation Act 1966 (ANA), the Civil Aviation Authority of Singapore Act 1984 (CAAS Act) and the Air Navigation Order 1985 (ANO) provide an adequate legal basis for the regulation of civil aviation in Singapore. There is an effective legal basis for the empowerment of the Director General of Civil Aviation (DGCA) and authorized personnel within the CAAS to implement the articles of the Chicago Convention and the SARPs contained in Annexes 1, 6, and 8 in accordance with relevant ICAO guidance material. However, written guidance for CAAS staff concerning the processing of cases of noncompliance with the ANA, CAAS Act, ANO and other regulatory instructions and directions, is not sufficiently detailed to enable staff to undertake enforcement action in a thorough, consistent and standardized manner. 3.1.2 The CAAS is an autonomous statutory body organized under the Ministry of Communications and Information Technology. The CAAS comprises sixteen divisions and one subsidiary. It is an appropriately staffed and adequately funded organization capable of accomplishing its functions and responsibilities effectively. The system for safety oversight is generally in conformity with ICAO requirements. Technical staff are properly qualified and supported by adequate policies, procedures, handbooks, facilities and equipment. However, further documentation of procedures and the inclusion in training documentation of the time interval for recurrent inspector training is needed. 3.1.3 The personnel licensing function is adequately supported by appropriate laws and regulations. The Personnel Licensing Section, which is responsible for all personnel licensing functions with respect to air crew and aircraft maintenance engineers, has adequate staff who have the appropriate qualifications and training to perform required tasks at the present level of activity. The CAAS has established and documented comprehensive policies and procedures concerning personnel licensing. These procedures are followed and result in the issuance and renewal of licences consistent with Annex 1. 3.1.4 The Flight Operations Section has established a system for the certification and supervision of international commercial air transport operators which generally conforms to the requirements of Annex 6. The system includes appropriate regulations, procedures, facilities and equipment. However, the present staffing policy has not sufficiently taken into account the numerous operations inspector responsibilities and the need for more operations inspections and flight checks. 3.1.5 The CAAS has established an effective aircraft airworthiness inspection system based on appropriate laws, regulations and procedures. However, there are no mandatory requirements for operators
- 3 - to prepare a minimum equipment list (MEL) although the CAAS requires commercial air transport operators in Singapore to include a MEL in the operations manual. 3.1.6 The CAAS effectively implements its safety oversight mission statement of safety, quality, and service through the regular monitoring of their industry to review compliance with rules and regulations. Inspectors display a professional approach in the execution of their duties from which a positive working relationship has developed with industry. There is a need for the CAAS to review internal procedures to ensure they are fully implemented. 3.2 Primary aviation legislation and civil aviation regulations in Singapore 3.2.1 Abstract of findings 3.2.1.1 The primary aviation legislation consists of the Air Navigation Act 1966 (ANA) and the Civil Aviation Authority Singapore Act 1984 (CAAS Act). Part II of the ANA empowers the Minister for Communications and Information Technology to enact provisions to implement the Chicago Convention and its Annexes and to generally regulate air navigation. This is done by way of order of the Minister and may include provisions pertaining to the safety, efficiency, and regulation of air navigation, the detention of aircraft, licensing or certification of personnel and operators, access to aerodromes and aircraft, and setting of fees. 3.2.1.2 The Air Navigation Order 1985 (ANO) constitutes the basic operating regulations related to the Annexes to the Chicago Convention. Other subsidiary legislation under the ANA is the Air Navigation (Investigation of Accident) Regulations and the Air Navigation (Licensing of Air Services) Regulations. The ANO requires compliance with three additional regulatory documents which are promulgated by the DGCA. They are the Air Operator Certification Requirements (AOCR), the Singapore Airworthiness Requirements (SAR), and the Singapore Air Safety Publication (SASP) which deals with air crew licensing. These documents implement the SARPs contained in Annexes 1, 6 and 8. Additional requirements pursuant to the provisions of the ANO are established through the issuance of Airworthiness Notices, Aeronautical Information Circulars (AICs) and Advisory Circulars. 3.2.1.3 Part III, Section 7(2) of the CAAS Act empowers the Minister to delegate to the CAAS any of his functions and powers under the ANA or its subsidiary legislation. The Minister has formally delegated the majority of his powers under the ANO to the CAAS. Among the few powers which are not delegated is the power to make regulations and, with some exceptions, the power to authorize exemptions from ANO provisions. Because the DGCA is empowered to promulgate and amend documents such as the AOCR, SAR and SASP, which have the effect of laws under the ANO, the retention by the Minister of the power to make regulations has not impeded the ability of the CAAS to implement regulatory requirements in a timely manner. 3.2.1.4 There are numerous regulatory provisions which adequately empower inspectors. Under the ANO, authorized persons have the right of access at all reasonable times to aerodromes, aircraft and documents for the purpose of inspection, and the power to detain aircraft for just cause. The powers, duties and responsibilities which are inherent in specific positions within the CAAS are specified in the relevant paragraphs of the Airworthiness/Flight Operations Procedures (AFOP), and are supported by a directive issued by the DGCA.
- 4-3.2.1.5 The CAAS has the responsibility of administering, implementing and enforcing compliance with the CAAS Act and ANA and the subsidiary legislation made under these Acts including the ANO. Paragraph 80 and the Thirteenth Schedule of the ANO specify penalties for non-compliance. Cases which may result in imprisonment and/or monetary penalties are investigated by the State police whereas cases which may warrant administrative action (against licences and certificates) are investigated and processed by the CAAS. 3.2.1.6 A brief description of enforcement policies and procedures is contained in the AFOP. The enforcement process is presently functioning at a basic level. Written guidance for CAAS staff concerning the processing of cases of non-compliance with the CAAS Act, ANA, ANO, and other regulatory instructions and directions, is not sufficiently detailed to enable staff to undertake enforcement action in a thorough, consistent and standardized manner. The CAAS is currently reviewing its enforcement policies and needs, and developing more detailed instructions and procedures for inspectors, in order to implement a more vigorous and effective enforcement programme. 3.2.2 Corrective action proposed/implemented by Singapore With respect to the recommendation that the CAAS develop and document comprehensive policies and procedures for processing cases of non-compliance with the CAAS Act, ANA, ANO and other regulatory instructions and directions, the CAAS indicated that draft procedures were completed on 15 November 2000 to ensure that enforcement functions are carried out in a thorough, consistent and standardized manner. The effective date of the new procedures is 1 January 2001. 3.3 Civil aviation organization system in Singapore 3.3.1 Abstract of findings 3.3.1.1 The CAAS Act defines the functions and authority of the CAAS and specifies that the CAAS has the responsibility for safety regulation of civil aircraft operations in Singapore and for the operations of Singapore-registered aircraft worldwide. 3.3.1.2 The CAAS is governed by a board consisting of a chairman, a chief executive officer and six to ten board members. The chief executive officer is the DGCA. The primary function of the board is to oversee the strategic planning and financial management of the CAAS. The DGCA is responsible for day-today operations and technical issues. 3.3.1.3 The CAAS is a statutory body under the Ministry of Communications and Information Technology. It is fully self-financing and controls its own revenues and expenditures. The CAAS is financially sound and independent, generating sufficient revenue from its operations to fund all its activities, including recruitment and training. The CAAS receives no additional funding from the government. 3.3.1.4 The CAAS comprises sixteen divisions and one subsidiary, the Singapore Changi Airport Enterprise (SCAE). Three deputy director-generals report to the DGCA. The Deputy Director-General for Operations is responsible for six divisions: Airworthiness/Flight Operations, Operations, Airport Emergency Services, Air Transport, International Relations/ICAO Affairs and the Singapore Aviation Academy. The division that has the primary responsibility for aviation safety oversight is the Airworthiness/Flight Operations (A/FO) Division.
- 5-3.3.1.5 The A/FO Division is composed of three sections entitled Flight Operations, Airworthiness, and Personnel Licensing. Each section has a section head/manager who is responsible for supervision and programme goals. The A/FO Division formulates policies and standards to be included in draft regulations and orders, and is responsible for the technical oversight of the civil aviation industry. All management personnel are experienced and adequately qualified for their jobs. 3.3.1.6 The A/FO Division is located at the Singapore Changi Airport and has a staff of thirty-two which includes sixteen airworthiness specialists, five operations specialists and one personnel licensing specialist. Terms of reference have been developed for all inspector positions. Remuneration and benefits for airworthiness inspectors are comparable to that of similarly qualified persons in industry although remuneration for operations inspectors is somewhat less than the industry standard. 3.3.1.7 A/FO Division personnel are supported by a system of inspector handbooks, but some procedures currently in use, such as the evaluation of wet and damp leases, the quarterly division of base inspection functions and the issuance of Export Certificates of Airworthiness, have not been documented. The present handbooks should be expanded to include institutional knowledge and internal procedures for all inspector job tasks. This is necessary in order to standardize inspector actions, to preserve institutional knowledge and for the training of new inspectors. 3.3.1.8 The A/FO Division has adequate office equipment and computers with Internet access. In addition, the staff has access to three technical libraries. The main technical library at CAAS headquarters is complete and comprehensive. The A/FO Division technical library also contains all necessary documents. The third library is located at the Singapore Aviation Academy. 3.3.1.9 CAAS inspectors are issued a credential granting unrestricted access to airports, aircraft and operator facilities. Vehicles with drivers are provided for official business by apron control motor pools. Employee records are maintained in separate filing systems for training, flight currency and personnel actions. 3.3.1.10 Training of inspectors is addressed in the AFOP which specifies general requirements for inspector indoctrination, recurrent training and specialized training. Recurrent courses are recommended, but the required courses and the time intervals for recurrent training are not specified. The training programme is currently implemented through the annual training plan for each employee. Funds are then allocated and training normally takes place as planned. 3.3.2 Corrective action proposed/implemented by Singapore With respect to the need to expand the present guidance material to document all institutional knowledge and internal procedures for inspectors, the CAAS indicated that new procedures for the evaluation of wet and damp leases have already been inserted in the AFOP. In addition, procedures for the quarterly division of base inspections functions have been amended in the AFOP and procedures have been inserted for the issuance of Export Certificates of Airworthiness. The time interval for inspector recurrent training has also been specified. The process of refining and expanding the scope of the AFOP to provide clear, concise and comprehensive guidance on CAAS policy and procedures is on-going. 3.4 Personnel licensing and training Singapore 3.4.1 Abstract of findings
- 6-3.4.1.1 The Personnel Licensing Section of the A/FO Division is responsible for all personnel licensing functions with respect to crew and aircraft maintenance engineers (AMEs). The manager is assisted by a flight operations inspector, a senior airworthiness manager, and four administrative personnel known as operations and licensing assistants. The Personnel Licensing Section has adequate office space and equipment. There is a clear line of authority, duties and responsibilities are defined in comprehensive duty statements and personnel are suitably qualified for their positions. 3.4.1.2 Training records maintained for each person contain a chronological list of the formal training taken and course completion certificates. These records indicate that Personnel Licensing Section personnel have received adequate formal training to perform their duties. A detailed training programme was recently implemented which is intended to formalize OJT requirements for all officers and support staff. 3.4.1.3 All licences and ratings contained in Annex 1 are currently issued by the CAAS, with the exception of private pilot licence (PPL) and commercial pilot licence (CPL) ratings for balloons, airships and gliders, and for flight navigator and flight dispatcher. The CAAS also issues flight engineer licences. Licence applicants must meet age, experience, knowledge, skill and medical requirements which are consistent with, or exceed, the requirements of Annex 1. 3.4.1.4 Examinations for pilot licences are conducted in accordance with detailed and comprehensive policies and procedures contained in Part II of the SASP and relevant chapters of the AFOP. Written examinations for pilot licences are prepared by UK International Services and administered by the CAAS. PPL examinations are evaluated by the CAAS while CPL and air transport pilot licence (ATPL) examinations are returned to the United Kingdom for evaluation. With some exceptions, applicants for initial issuance of a PPL or ATPL are required to undergo a general flight test conducted by a CAAS flight operations inspector or authorized flight examiner (AFE). 3.4.1.5 Although licences are not required for flight dispatchers in Singapore, operators are required to issue Certificates of Competency to dispatchers based upon successful completion of an approved training, qualification or re-qualification programme which is consistent with the requirements of Annex 1, paragraph 3.3. 3.4.1.6 Examinations for AME licences are conducted in accordance with comprehensive policies and procedures in the SAR and the AFOP. AME licences are granted for aircraft on the Singapore register in five categories: aircraft, engines, electrical installation, instrument installation and radio systems. Written examinations for AME licences are prepared, administered and evaluated by the CAAS. 3.4.1.7 Written examinations for type ratings are prepared, conducted and evaluated by the Engineering and Training Department of Singapore Airlines under a programme approved and monitored by the CAAS. 3.4.1.8 Singapore does not currently issue ATC licences but plans to in the future. The age, knowledge, experience, skill and medical requirements in the relevant provisions are consistent with Annex 1, paragraphs 4.3 and 4.4. 3.4.1.9 The ANO authorizes the CAAS to issue a certificate of validation for flight crew licences and AME licences issued by another State. The SASP addresses the conversion of licences issued by another State. The conversion terms for each applicant are established on a case-by-case basis depending upon the
- 7 - flying experience, the nature of past employment and the specific conditions under which the licence was issued. The SASP contains policies and procedures concerning the temporary validation of PPLs and ATPLs issued by another State. Such validations are usually authorized to allow a pilot to undergo training to obtain a Singapore licence, and the period of validation does not normally exceed six months. The CAAS requires written confirmation from the relevant CAA concerning the legitimacy of a licence issued by another State which is to be validated or converted. The CAAS may also examine the Supplement to Annex 1 for differences filed by the relevant State and coordinate with the relevant CAA. 3.4.1.10 Medical examinations for all classes of licences are conducted by Designated Medical Examiners (DMEs) appointed by the CAAS. Requirements for appointment as a DME include formal training in aviation medicine. DMEs are required to attend professional seminars and other training courses arranged for, or conducted by, the Civil Aviation Medical Boardof the CAAS, and are required to conduct a minimum number of examinations annually to retain their designation. A list of current DMEs is published each year in an AIC. 3.4.1.11 Licences are of the expiring type and the format conforms to Annex 1, Chapter 5. Prior to renewal, professional crews are required to show evidence of compliance with Annex 1, including recency of experience, recurrent training, proficiency checks and medical qualification. Either a Certificate of Test or Certificate of Experience is required for renewal, and the certificate must reflect the minimum requirements corresponding to the aircraft rating. The SASP contains policies on reinstating the privileges of lapsed licences. 3.4.1.12 The military (RSAF) and the Singapore Flying College are the two main sources of professional pilots within Singapore. The Singapore Flying College, which is a subsidiary of Singapore Airlines, is approved to conduct training through the CPL level. Comprehensive guidance for approval of aviation training institutions is contained in the AFOP and in an AIC. 3.4.1.13 In addition to the Singapore Flying College, there are three recreational flying clubs which are authorized to provide flight and ground training for PPL. These clubs are required to submit training syllabi for approval with their operations manuals and are inspected annually. 3.4.1.14 To meet requirements for conducting type ratings and proficiency checks at training institutions (including Singapore Airlines) the CAAS has appointed AFEs. Guidance for the appointment of AFEs is contained in the AFOP and in an AIC. SASP 7 provides guidance to AFEs concerning the performance of their duties. An orientation briefing for AFEs has recently been initiated by the CAAS to provide information concerning the powers and duties of examiners. AFEs are normally appointed for two year terms. 3.4.1.15 Examiners at Singapore Airlines are required to hold a flight instructor s rating, meet minimum experience requirements, and undergo a course of approved training for flight examiners which is conducted by the airline. Applicants for designation as AFEs are observed performing examinations by another AFE before being designated by the CAAS. There is no policy, however, which requires that AFE applicants be observed performing examinations by the CAAS inspectors or by a senior AFE specifically authorized by the CAAS for that purpose before initial designation or for renewal of their authority. Flight checks are not performed before initial appointment. The AFOP specifies that designated examiners should be flight checked at least every three years, rather than annually as recommended in ICAO guidance material.
- 8-3.4.2 Corrective action plan proposed/implemented by Singapore With respect to the recommendation that applicants for designation as AFEs be observed by CAAS inspectors or by a senior AFE specifically authorized by the CAAS, conducting the type of examination for which approval is sought, the CAAS indicated that the industry has already been advised of this new requirement through the issue of an AIC, and a revised Singapore Air Safety Publication (SASP) Part 7 with an effective date of 1 April 2001. In addition, the AFOP has already been amended to reflect this requirement and the inclusion of the appointment of designated senior AFEs to conduct such checks will be introduced in May 2001. 3.5 Aircraft operations certification and supervision in Singapore 3.5.1 Abstract of findings 3.5.1.1 The ANO empowers the DGCA to establish requirements for the issuance of air operator certificates (AOCs) and states that an AOC must be issued to conduct public transport operations in Singapore. The Air Operator Certificate Requirements (AOCR) provides the regulatory requirements for AOC issuance and serves as an inspector handbook and information package for prospective applicants. Additional requirements are found in supporting technical documents such as the SASP. All these documents contain aviation safety requirements which are have been officially notified to the public and are considered regulatory. The regulations address all the requirements of Annex 6. 3.5.1.2 The A/FO Division is responsible for the safety oversight of aircraft operations conducted in Singapore. This includes the certification and supervision of certificated air operators as well as any necessary enforcement actions. The Flight Operations Section is organized under the leadership of a Section Head who supervises four full-time operations inspectors. Terms of reference are available for all technical personnel. The operations inspectors are assisted by four clerical personnel shared by the entire A/FO Division. 3.5.1.3 Although Singapore Airlines operates four Learjets for advanced training, there are no operations inspectors rated on this aircraft. There is one helicopter operator in the State, operating two helicopters, but there are no inspectors who are helicopter rated. An agreement has been reached with Malaysia to provide the services of a helicopter rated inspector when required. 3.5.1.4 The manager of the Personnel Licensing Section, who is also an inspector, provides assistance to the Flight Operations Section. This inspector is responsible for scheduling helicopter surveillance and is the primary person responsible for cabin safety and dangerous goods concerns. 3.5.1.5 According to the current hiring plan, the A/FO will be allocated one additional operations inspector position in 2004. The present staffing policy has not sufficiently taken into account the numerous operations inspector responsibilities, such as managerial duties, rotorcraft operations, business aviation, advanced training on jet aircraft, the oversight of foreign-registered aircraft, the development and drafting of State operations regulations and procedures, and so on. Furthermore, there is presently a need for a considerable increase in the number operations inspections and flight checks performed each year. These inspections are required in order to comply with ICAO guidance material concerning designated examiners and to provide a statistically meaningful sampling of operations activities.
- 9-3.5.1.6 Operations inspectors are supported by an adequate infrastructure of office space and equipment. Inspectors are issued credentials that provide unrestricted access to airports, operators and aircraft. There also is an adequate system of personnel files. 3.5.1.7 The certification of air operators is accomplished using a conventional five-step process involving pre-application, formal application, document evaluation, demonstration and awarding of the AOC. The process is conducted by a team of A/FO inspectors with appropriate specialties. Financial fitness and economic authority are assessed by the CAAS Air Transport Division. 3.5.1.8 Included with the AOC are operations specifications named AOC Appendix 1 and 2. These operations specifications do not provide the detail or scope recommended in ICAO Doc 8335, paragraph 7.2 and Attachment B. 3.5.1.9 AOCs are issued for a period of one year and cannot be extended or renewed. Prior to expiration, holders of AOCs must apply for a subsequent AOC which is issued based on the results of routine CAAS inspections. The certification process used for the initial certification of an operator is also used for the addition of an aircraft type to an existing operation. These certification procedures are described in the AOCR. 3.5.1.10 Operations inspectors carry out periodic inspections of air operator bases, line stations and aircraft. They also visit handling agents appointed by the operator. These checks are conducted to assess the suitability of an operator s organization, base facilities, overall standards of operation and level of compliance with regulatory and operations manual requirements. The AFOP specifies the minimum number of inspections to be accomplished annually and provides checklists for inspector use. En-route and line station inspections are planned and budgeted for on an annual basis. The other inspections are conducted without a schedule and no work plan is established. Air operator base inspections are completed annually through four inspection visits. 3.5.1.11 The minimum number of inspections recommended in ICAO guidance material is used as a target for the Flight Operations Section without regard to the high volume of flights conducted by State operators. Considering the size and complexity of the State air operators, a surveillance plan should be developed based on a percentage of total flights conducted, rather than only four inspections per type, per year. A written inspection work plan should be developed for each operator, and not just by aircraft type. 3.5.1.12 A review of the inspection records for the last two years revealed that the Flight Operations Section did not achieve the objectives of the AFOP in terms of the number of inspections/audits performed each year. The number of ramp inspections conducted is low compared to the total number of aircraft operated. 3.5.1.13 After inspections, completed checklists are filed in air operator folders. Inspections are also recorded in a simple database. There is no system for tracking or analysis of inspection data. Considering the size and complexity of the State air operators, it would be beneficial to develop such a system for use by the Flight Operations Section and throughout the CAAS. 3.5.1.14 The Flight Operations Section is assisted in its certification and surveillance functions by seventy-eight designated examiners who conduct flight checks for type ratings and proficiency checks. Minimum criteria for appointment and examiner procedures are specified in the AFOP. Designated examiners
- 10 - must undergo instructor training prior to appointment in accordance with company requirements. Flight checks are not performed before initial appointment. The examiner designations normally expire every two years. The AFOP specifies that designated examiners should be flight checked at least every three years, rather than annually as recommended in ICAO guidance material. 3.5.2 Corrective action plan proposed/implemented by Singapore 3.5.2.1 With respect to the need to recruit and train additional qualified inspectors, the CAAS indicated that it has reviewed the parameters and formula to calculate the required number of flight operations inspectors. The CAAS Staff Committee has approved an additional three flight operations inspectors to augment the current number of inspectors and has approved the use of the new formula for future increases. The recruitment process has now been initiated by CAAS A/FO and HR Divisions, and the aim is to recruit the three flight operations inspectors between July and October 2001. 3.5.2.2 Regarding the need to expand the present operations specifications to incorporate guidance material in ICAO Doc 8335, paragraph 7.2 and Attachment B, the CAAS indicated that Appendix A of the AOCR has been amended and became effective on 15 December 2000. All Singapore AOC holders have been issued the new AOC. 3.5.2.3 With respect to the need to develop additional requirements and procedures for a documented annual surveillance work plan to reinforce the supervision system, the CAAS indicated that it has revised the annual surveillance work plan to include ramp, enroute, line station and AFE inspections (AFOP Section 5, Chapter 8). The CAAS intends to increase the number of inspections as more flight operations inspectors are recruited, taking into account the scope, size and complexity of the operators. In particular, designated flight examiners will be checked once a year. 3.6 Airworthiness of aircraft in Singapore 3.6.1 Abstract of findings 3.6.1.1 The ANA and the CAAS Act provide the legal basis for airworthiness orders and for the regulation of airworthiness activities in Singapore. Requirements and procedures are stipulated in the ANO and address airworthiness-related issues, such as the registration of aircraft, Certificates of Airworthiness, certificate of release to service and AOCs. Section 2 of the SAR contains further guidance for the issue of Certificates of Airworthiness. 3.6.1.2 SAR 145 provides the requirements and procedures for approved maintenance organizations (AMOs). Those requirements include a quality control system, maintenance procedures manual, facilities, qualification and training of personnel and associated procedures. SAR 145 also requires AMOs to produce manpower plans to ensure staffing levels are adequate for the work undertaken, but such plans are not being submitted to the CAAS. 3.6.1.3 The Airworthiness Section of the A/FO Division is managed by a section head and comprises fourteen technical staff divided into four groups. The Operator Group is responsible for AOC matters. The Maintenance Organization and Aerospace Organizations Groups are responsible for AMOs for aircraft and engines, and equipment and components, respectively. The Technical Group is in charge of modifications and major repairs.
- 11-3.6.1.4 The scope of the work of the Airworthiness Section encompasses the 135 aircraft registered in Singapore. Singapore has three AOC holders: Singapore Airlines (SIA), operating a fleet worldwide of 104 aircraft; SilkAir, operating as a regional carrier with a fleet of six aircraft; and ST Aerospace Engineering, operating two Bell 206 helicopters. ST Aerospace Engineering also operates as an AMO. 3.6.1.5 There are eighty-four AMOs approved under SAR 145. Sixty-five of these are located in Singapore and nineteen are located in other States. There are four aircraft parts and equipment manufacturers in Singapore but these are under another State s primary certification. 3.6.1.6 Airworthiness inspectors are responsible for airworthiness regulations, aircraft maintenance control, aerospace organization control, defect analysis, personnel licensing and aircraft accident investigation. The CAAS has established a comprehensive training programme for basic, specialized and recurrent training for airworthiness inspectors and engineers in accordance with the AFOP. However, as the interval of the recurrent training is not specified, it could not be determined if the recurrent training of some inspectors had been conducted according to a pre-determined time interval. 3.6.1.7 The CAAS technical library provides Internet access to other libraries and sources for aviation information worldwide and retains ICAO documents, manufacturer manuals, operator manuals and maintenance organization manuals. However, information describing how the technical library is organized and operated has not been made available. Airworthiness technical documents, are stored on microfilm cassettes. Temporary revisions to microfilm cassettes are distributed to technical personnel, but are not returned to the library to be formally recorded as amendments and are therefore not readily accessible. 3.6.1.8 Continuing airworthiness functions are described in the SAR, which is supplemented by Airworthiness Notices and Advisory Circulars. Procedures and guidance for continuing airworthiness tasks, including certification procedures, are contained in the AFOP. Safety oversight activities include monthly meetings, in-house and with the AOC holders, on reliability control, airworthiness directive compliance and incident review. ETOPS reliability is reviewed every three months. Certificates of Airworthiness are renewed on an annual basis. 3.6.1.9 The AFOP manual does not include a procedure for the issue of an Export Certificate of Airworthiness. 3.6.1.10 The CAAS has not established a system to issue mandatory airworthiness information concerning aircraft designed and manufactured in other States. However, operators are required to comply with mandatory airworthiness information, such as airworthiness directives issued by other States. 3.6.1.11 Chapter 2.2 of the SAR states that aircraft certificated by the United States Federal Aviation Administration, the United Kingdom Civil Aviation Authority, the European Joint Airworthiness Authority or Transport Canada, in accordance with their respective detailed and comprehensive airworthiness codes, are acceptable for certification in Singapore. 3.6.1.12 Chapter 4.3 of the SAR provides a comprehensive list of items that owners and operators are required to include in aircraft maintenance schedules before approval of maintenance programmes. However, there is no requirement to ensure that the maintenance programmes of aircraft that are operated by AOC holders in Singapore and registered in another State are approved by the State of Registry.
- 12-3.6.1.13 The CAAS requires commercial air transport operators in Singapore to include in the operations manual a minimum equipment list (MEL) for obtaining an AOC, as indicated the AOCR, however, the existing national regulations on MELs do not make it mandatory. 3.6.2 Corrective action plan proposed/implemented by Singapore 3.6.2.1 With respect to the recommendation that SAR 145.30 be amended to require AMOs to submit to the CAAS manpower plans indicating that there is sufficient personnel to plan, perform, supervise, inspect and release work, the CAAS indicated that it has already notified AMOs of this requirement through the issuance of an Advisory Circular. The AFOP has also been expanded to provide guidance on the review of man-hour plans on a three-month basis. 3.6.2.2 With respect to the need to establish procedures to ensure that documents in the technical library are kept up-to-date and that information is made available relating to the organization and operation of the technical library, the CAAS indicated that the AFOP has already been amended to include procedures relating to the updating of technical manuals and information and airworthiness data contained in microfilms has been amended to indicate the affected temporary revisions. The technical officer in charge of the library has been sent for a training attachment to the SIA Technical Library to familiarize him with the operations of a large technical library. 3.6.2.3 With respect to the recommendation that the SAR be amended to require approval by the State of Registry of maintenance programmes where aircraft are operated by AOC holders in Singapore but registered in another State, the CAAS noted that, at the current time, there are no Singapore operators operating foreign-registered aircraft. However, in the event that Singapore operators do operate foreign-registered aircraft in the future, the SAR and AOCR have been appropriately amended with an effective date of 15 December 2000. The AFOP has also been amended to include the evaluation of the terms of approval carried out by the foreign authority. 3.6.2.4 With respect to the recommendation that the regulations be amended to specifically require commercial operators to develop a MEL for all aircraft registered and operated in Singapore, to be approved by the CAAS, the CAAS noted that it does not currently permit commercial operations without a MEL and the AOCR states that air operators should provide a MEL for each aircraft. In order to make this explicit, Chapter 2 of the AOCR has been amended to mandate all operators to have a MEL for each aircraft. 4. COMMENTS As indicated above, Singapore submitted a revised action plan on 5 April 2001, addressing all the findings and recommendations that were forwarded, including comments and feedback on the revised interim report sent on 20 February 2001. An attempt has been made in this report to reflect the action plan proposed by Singapore along with the comments and feedback which were provided on the interim report. 5. STATUS OF IMPLEMENTATION AND DIFFERENCES FROM THE ICAO SARPs Differences identified during the audit are found in Appendices A and B to this summary report and differences vis à vis Standards will be included in the relevant Annex Supplement in line with
- 13 - Article 17 of the MOU signed between Singapore and ICAO. It was noted that no differences exist between the national regulations and Annex 8 SARPs.
APPENDIX A STATUS OF IMPLEMENTATION AND LIST OF DIFFERENCES FROM THE ICAO STANDARDS (ANNEX 1 PERSONNEL LICENSING) ICAO Standard reference Singapore s regulations reference Differences between the national regulations of Singapore and ICAO Standards 2.3.2.1 ANO PPLs contain restrictions of privileges for cross-country flights. 2.3.2.2 ANO A night rating shall be issued to PPL holders who have completed five hours of night flying training and meet the necessary flying experience requirements. 2.11 ANO An assistant flying instructor rating with restricted privileges is issued to a newly qualified flight instructor. 2.12.1.1 ANO An applicant for a CPL shall not be less than 18 years of age. 2.13.1.1 ANO An applicant for a PPL for balloons and airships shall not be less than 17 years of age. An applicant for a CPL for balloons and airships shall not be less than 18 years of age. 3.2.1.1 ANO An applicant for a flight navigator licence shall not be less than 21 years of age. 3.3.1.1 ANO An applicant for a flight engineer licence shall not be less than 22 years of age. 4.5 ANO Singapore does not issue flight operations officer/flight dispatcher licences. However, flight operations officers/flight dispatchers must meet Annex 1 requirements. 4.6 ANO Singapore does not issue aeronautical station operator licences.
A-2 STATUS OF IMPLEMENTATION AND LIST OF DIFFERENCES FROM THE ICAO STANDARDS (ANNEX 6 OPERATION OF AIRCRAFT) (PART II International General Aviation Aeroplanes) ICAO Standard reference Singapore s regulations reference Differences between the national regulations of Singapore and ICAO Standards 6.1.1 General aviation aircraft in Singapore are required to be registered in the public transport category. END