AUDIT SUMMARY REPORT OF THE CIVIL AVIATION AFFAIRS THE STATE OF BAHRAIN

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1 ICAO Universal Safety Oversight Audit Programme AUDIT SUMMARY REPORT OF THE CIVIL AVIATION AFFAIRS OF THE STATE OF BAHRAIN (Manama, 4 to 12 August 2000) INTERNATIONAL CIVIL AVIATION ORGANIZATION

2 ICAO UNIVERSAL SAFETY OVERSIGHT AUDIT PROGRAMME Audit Summary Report on the Safety Oversight Audit Mission to Bahrain (Manama, 4 to 12 August 2000) 1. BACKGROUND 1.1 The Civil Aviation Affairs (CAA) of the State of Bahrain was initially assessed under the voluntary ICAO Safety Oversight Assessment Programme from 30 November to 4 December 1996 by an ICAO assessment team. This audit was carried out from 4 to 12 August 2000 pursuant to Assembly Resolution A32-11 and in accordance with the updated Memorandum of Understanding (MOU) agreed on 30 May 2000 between Bahrain 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 CAA of Bahrain. The audit also aimed to ensure that Bahrain 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 18 December 2000, Bahrain 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 submitted was reviewed by the Safety Oversight Audit (SOA) Section and was found to be satisfactory. On 24 January 2001, 20 March 2001 and 26 May 2001, Bahrain submitted further updates on the progress made in the implementation of its corrective action plan and, on 7 May 2001, Bahrain also forwarded an update on the status of implementation and list of differences from ICAO SARPs. The action plan submitted, along with the updates, have been taken into consideration in the preparation of this audit summary report. 2. CIVIL AVIATION ACTIVITIES IN BAHRAIN At the time of the audit the civil aviation activities in Bahrain included: a) number of technical staff employed by the organization at Headquarters 7 b) number of active pilot licences 36 c) number of active flight crew licences other than pilot licences 13 d) number of active licences other than flight crew licences 34 e) number of commercial air transport operators 1 f) number of air operator certificates (AOCs) issued 1 g) number of aircraft operations inspectors 1

3 - 2 - h) number of aircraft registered in Bahrain 6 i) number of Certificates of Airworthiness (C of A) issued 6 j) number of approved maintenance organizations (AMOs) 8 k) number of aircraft maintenance workshops 6 l) number of design organizations 3 m) number of aircraft airworthiness inspectors 2 3. SUMMARY OF FINDINGS 3.1 General statement The State of Bahrain Civil Aviation Law, promulgated in 1995, establishes the Civil Aviation Affairs (CAA) as a department of the Ministry of Transportation. The Undersecretary of the CAA is the Chief Executive Officer; however, rule making and amendment authority is retained by the Minister. The Civil Aviation Law provides adequate enforcement provisions and authority to the CAA. In accordance with the Civil Aviation Law, the Minister of Transportation has issued the Air Navigation Technical Regulations (ANTR) and a Technical Procedures Manual has also been issued by the Undersecretary of the CAA to provide subsidiary regulations and CAA procedure. The ANTR do not conform in all respects with ICAO SARPs Bahrain has established an adequate CAA structure which enables it to satisfactorily undertake most of its assigned tasks. The operations, airworthiness and personnel licensing groups are organized under the Aircraft Registration and Licensing Section (ARL). The inspector groups are short-staffed in some cases and salaries remain significantly lower than that provided to similarly qualified personnel in industry. The ARL section has not developed a comprehensive training programme for its inspectors. There is also a lack of adequate equipment such as computers, telephones and vehicles The CAA has established a basic system for personnel licensing. Guidelines and procedures are also developed for the issuance of licences to holders of a foreign licence and for the validation of foreign licences. The personnel licensing regulations, however, do not conform in all respects with provisions of Annex 1 and associated guidance material. Areas requiring further improvement in the personnel licensing system include aircraft maintenance and air traffic controller licences; supervision of designated medical examiners; certification and supervision of training institutes; and criteria for designating examiners The Flight Operations Inspection Group (FOIG) is charged with the certification and supervision of air operators and also with the development of flight operations policies, procedures, and regulations. The group has been staffed by only one person for the last four years. The FOIG lacks a comprehensive training and flight currency programme, as well as required additional procedures and equipment. Notwithstanding the effort made by the single officer, there is a lack of adequate resources for the CAA to satisfactorily undertake its safety oversight responsibilities related to operations.

4 With respect to airworthiness activities, Bahrain has established adequate regulations, procedures and checklists including enforcement provisions and inspection authority. However, the regulations do not fully conform to ICAO SARPs and associated guidance material. The Airworthiness Inspection Group (AIG) is minimally staffed. The Group lacks essential office tools and equipment such as computers, long distance telephone access and government transportation. There is also no adequate training programme to prepare inspectors for the proper discharge of their responsibilities. 3.2 Primary aviation legislation and civil aviation regulations in Bahrain Abstract of findings The Civil Aviation Law is the primary aviation legislation in Bahrain. In addition, Amiri Decrees are promulgated by the Amir, the Head of the State. The power to issue rules for the execution of the Civil Aviation Law has been given to the Minister of Transportation. The legislation does not provide for the Undersecretary for the CAA to delegate the authority to amend the ANTR, or to issue procedures, orders, instructions or directives. Nevertheless, many of these documents have been issued by senior officials at the CAA Enforcement provisions are contained in the Civil Aviation Law and allow for the revocation and suspension of licences and certificates, monetary fines and jail sentences. The CAA experience in this regard has thus far been limited to suspensions only The Civil Aviation Law does not make provision for the implementation of Article 83bis, which was ratified by the State of Bahrain in In accordance with the Civil Aviation Law, the Minister of Transportation issued the ANTR in June Overall, the regulations do not fully conform with relevant ICAO SARPs, and specific amendment procedures have not been developed. There are no procedures established to review amendments to the ICAO SARPs, to implement changes in the Regulations or to notify differences to ICAO A Technical Procedures Manual has been issued by the Undersecretary for the CAA. This manual serves both as subsidiary regulations, and also as CAA procedure. The contents of the manual includes basic regulatory requirements that should in fact be included in the Regulations. Supplementary regulations such as directives and orders are very minimal or non-existent Corrective action proposed/implemented by Bahrain With regard to the recommendation that the CAA develop a formal procedure for the future amendment of the ANTRs in order to ensure implementation of all ICAO SARPs, including provisions for listing and notifying differences to ICAO, the CAA indicated that these provisions were incorporated as Articles 78 and 79 of Amendment No. 7 of the ANTR, issued in December With respect to the recommendation that the CAA amend its legislation in order to fully implement the provisions of Article 83 bis, the CAA indicated that this has been accomplished by the issuance of Article 80 of Amendment No. 7 of the ANTR, issued in December In its action plan, the CAA indicated that it will review and amend the ANTRs to incorporate all of the existing ICAO SARPs and their amendments by the end of December 2001.

5 Amiri Decree No. 5 dated 31 January 2001 has amended the Civil Aviation Law to extend the power to issue rules for the execution of the Civil Aviation Law to the representative of the Minister of Transportation as well. 3.3 Civil aviation organization system in Bahrain Several CAA directorates are established under the Assistant Undersecretary for Aviation Services. These include the Air Transport Directorate, the Air Navigation Directorate and the Meteorology Directorate. The Assistant Undersecretary for Aviation Services reports to the Undersecretary for the CAA who, in turn, reports to the Minister of Transportation. The Undersecretary for the CAA is entrusted with the responsibility to implement the ANTR. Other duties and responsibilities of the Undersecretary, however, are not described in any document The Aircraft Registration and Licensing Section (ARL), under the Director of Air Transport, has been assigned primary responsibilities for the certification and supervision of the civil aviation industry. The ARL section consists of the Flight Operations Inspection Group (FOIG), the Airworthiness Inspection Group (AIG) and the Aviation Licensing Group (ALG). All groups combined have a total of six inspectors and two clerical personnel. One of the two flight operations inspector positions has been vacant for four years. All of these personnel are based at the CAA Headquarters which is located at the airport. There are no regional offices. The number of staff assigned to the CAA is insufficient for its responsibilities The ARL section has two posts for administrative support personnel, but these positions have not been given full time employment status and are frequently vacant. The incumbent of one of the two administrative posts is the primary person charged with the oversight of dangerous goods for the CAA. The ARL section is supported by a system of inspector guidance and standard office equipment. However, the inspectors have not been provided with all of the tools necessary to carry out their functions such as computers, long distance telephone lines or government vehicles Financial resources for the CAA are allocated by the government s federal budget based on the CAA s annual forecasting requirements. While the CAA budget allotment is adequate for current operations, some responsibilities of the CAA remain unimplemented due to a shortage of funds Salary scales are established by the State Civil Service Bureau and thus technical personnel at the CAA receive salaries commensurate with those of other civil service groups; however, these salaries are significantly lower than those provided to similarly qualified personnel in the aviation industry. As a result, there is a high turnover and the CAA experiences continued difficulties in filling the vacant posts The CAA has not developed a comprehensive written policy or formal training programme for the operations, airworthiness or personnel licensing inspectors. There is no standardized inspector initial or recurrent training, and courses are provided only on an irregular basis. Newly hired inspectors are given individually tailored career development plans which may span several years. However, this does not include on-the-job training to ensure inspector competence on individual job functions. Recurrent training is similar to initial, and no requirements are specified for inspector currency. Inspectors are typically scheduled for one course each year, but actual attendance is awarded on an irregular basis. Moreover, many courses do not take place as funds allocated for training in the annual budget are often diverted for other uses.

6 The ARL section has been designated to carry out aircraft accident investigations and also to determine the probable causes. This dual role could at times create a conflict of interest, with CAA personnel investigating and establishing the primary cause of accidents within the industry they regulate The CAA is provided with consultation services by the United Kingdom Civil Aviation Authority under contract. United Kingdom inspectors normally visit Bahrain once a year for three days to provide an overview assessment of activities and advise on technical matters. These inspectors are not involved in the daily technical activities of aviation safety oversight in Bahrain Corrective action proposed/implemented by Bahrain In response to the recommendation that the CAA improve the remuneration of its technical staff to ensure that it is able to attract and retain qualified personnel, and ensure that funds allocated for training are not diverted to other uses, the CAA indicated that this recommendation will be implemented by the end of With respect to the recommendation that additional funding be provided to allow the CAA to effectively and efficiently fulfill its safety oversight obligations, the CAA indicated that this would be accomplished by the end of With regard to the recommendation that the government of Bahrain establish an independent agency to investigate aircraft accidents, the CAA noted that a High Council for Aviation presently oversees accident investigations. In addition, a separate Aviation Safety Section will be established by the end of 2001 that will report directly to the Undersecretary of the CAA In accordance with a recommendation that the CAA develop a comprehensive training programme for inspector personnel, including all appropriate curriculums and record keeping, the CAA indicated that this programme will be implemented by December In its action plan, the CAA agreed to provide inspectors with all of the tools necessary for the execution of their essential duties, including personal computers with Internet access, computer training, long distance telephone lines, and government vehicles equipped with airport passes for the conduct of official business, by 30 June 2001.

7 Personnel licensing and training Bahrain Abstract of findings Issuance of personnel licences is governed by the Civil Aviation Law, and personnel licensing regulations are contained in the ANTR. A system of procedures issued by the Assistant Undersecretary for Aviation Services has been developed to provide for the uniform interpretation and application of the ANTR. However, not all provisions of Chapters 5 and 6 of Annex 1 have been implemented and the ANTR and associated procedures have not been amended to keep pace with Annex 1 SARPs The Aviation Licensing Group (ALG) has two technical staff, one Licensing Specialist and one Senior Licensing Specialist, who are responsible for the day-to-day administration of all licensing activities. They each have a copy of the ANTR and of Annex The ANTR provide for the issuance of the following licences: private pilot (aeroplane), commercial pilot (aeroplane), airline transport pilot (aeroplane), private pilot (helicopter), commercial pilot (helicopter), and flight engineer. Licences for air traffic controller, flight dispatcher, glider pilot or free balloon/airship pilot are not currently issued. Licences issued are of the expiring type, valid for five years or until the date of expiry of the medical assessment. Pilot licence holders are required to pass a medical fitness examination and to comply with recency of experience requirements to obtain a licence renewal Procedures and requirements to validate foreign licences or to issue national licences based on foreign licences have not been published in the AIP The ANTR provide for the issuance and validation of the Aircraft Maintenance Engineer licence but do not fully conform to paragraph 4.2 of Annex 1. There are no procedures to ensure compliance with requirements established to obtain an Aircraft Maintenance Engineer licence For Air Traffic Controllers, the State of Bahrain has authorized SERCO International Aeradio Limited (IAL) to issue Air Traffic Control certificates of competency, and to provide a regulatory system for the conduct of air traffic services. The training course provided by the company is not approved by the CAA. Also, the ANTR do not contain all provisions of paragraphs 4.3 and 4.4 of Annex 1. Procedures to implement the requirements for the issuance of a national Air Traffic Control licence are lacking Two aviation medical examiners have been designated by the CAA to conduct medical checks for flight crews. There is no system in place for evaluating medical reports issued by the examiners. There are no provisions on measures to be taken in case of reported false medical declarations made by applicants. Also, the circumstances under which a medical examination may be deferred, and the period of deferral, are not specified Standards, policies and procedures have been established for the certification and supervision of designated flight test examiners. However, no procedures or criteria have been established concerning written and oral examinations The Civil Aviation Law stipulates that operators are required to provide appropriate training programmes, approved by the CAA, to their flight crew members as well as to the handling agents, in order to ensure the proper performance of their duties. In June 1999, the CAA established procedures, addressed

8 - 7 - to air operators only, for the Inspection and Approval of Training Organizations, Flight Simulators and Other Training Devices. The requirements, however, do not extend to the certification and supervision of private, ab initio, or foreign training institutes where Bahraini nationals receive training Corrective action proposed/implemented by Bahrain With regard to the recommendation that the CAA review the personnel licensing regulations in order to implement all the provisions of Annex 1, the CAA indicated that this review is underway and will be completed by 30 June With respect to the recommendation that the CAA review the provisions of Article 10 of the ANTR and associated procedures to ensure compliance with all the provisions of paragraph 4.2. of Annex 1, and establish a system for the issuance of Bahrain Aircraft Maintenance Engineer licences, the CAA indicated that the appropriate regulations have been revised in Amendment No. 7 of the ANTR issued in December The necessary procedures will be developed by 30 September In accordance with the recommendation that the CAA review and amend the provisions of paragraph D1 of Schedule 8 of the ANTR and its associated procedures to ensure compliance with the provisions of paragraphs 4.3. and 4.4. of Annex 1, and establish a system for the issuance of Bahrain Air Traffic Controller licenses, the CAA indicated that the necessary provisions have been introduced in Amendment No. 7 of the ANTR issued in December Associated procedures will be established by 30 September In response to the recommendation that the CAA establish a system for the assessment of medical reports issued by State medical examiners, including the actions to be taken in the case of reported false medical declarations made by applicants, and provisions for the deferral of medical examinations, the CAA indicated that it has revised procedure ARL/GEN/05 in Issue No. 5 of April 2001 in order to implement this recommendation The CAA indicated that it has now established regulations and associated procedures (ARL/OPS/06 Appendix 1 of April 2001) in order to implement a system for the certification and supervision of all training institutes and/or aviation schools, to include private and ab initio schools, and foreign training institutes where Bahraini nationals receive training In order to implement the recommendation that the CAA develop comprehensive criteria for the designation and control of Designated Examiners, and procedures for the development and control of written examinations, the CAA has issued the revised procedures P01/09 Issue 2 of May 2001 and ARL/GEN/07 Issue 1 of April 2001 in order to implement this recommendation With regard to a recommendation concerning the physical aspects of State licenses, the CAA indicated that it has reviewed the format of all State licences to ensure full conformance to the ICAO standards as set forth in Chapter 5 of Annex 1 (Schedule 8, Part E of Amendment No. 7 of the ANTR, issued in December 2000, refers) In its action plan, the CAA indicated that it has published in its AIP the State procedures for the issuance of licences on the basis of a foreign licence and for the validation of foreign licences. Differences between State personnel licensing regulations and the SARPs contained in Annex 1 will be notified to ICAO and significant differences have been published in AIP (AIRAC 13 dated 17 May 2001).

9 Aircraft operations certification and supervision in Bahrain Abstract of findings Regulations pertaining to aircraft operations are found in the ANTR, Parts 1 to 8, which were last amended in June Additional regulations are included in Procedures and Publications documents, numbered P01/01 to P01/ The present regulations do not address some important aspects of aviation safety such as threshold crossing heights, ETOPS, daily flight and duty time limits, and all aspects of GPWS. Although procedures exist in practice for some of these items, there is no legislation requiring their full implementation The Flight Operations Inspection Group (FOIG) is responsible for the certification and ongoing supervision of air operations in Bahrain. The FOIG has been allocated two inspector posts; however, one of the posts has been vacant for the last four years. The post designated for the Head of the ARL section is also vacant, thus the Senior Flight Operations Inspector is also acting as Section Head. He is, in fact, the sole person responsible for carrying out all the functions of the section, such as certification and supervision of air operators, and is required at the same time to develop operations regulations, policies and procedures Initial inspector training programmes are limited to a personalized career development plan, and there is no formal briefing or on-the-job training. A system to verify competency on inspector s individual job tasks, or to determine the training courses needed to advance to journeyman status, is lacking. Neither a formal recurrent training programme nor a system of flight currency are available. Additionally, since the current Flight Operations Inspector is an expatriate, the Civil Service Bureau considers him fully trained and allocates no funds for his recurrent training or flight proficiency. His training is limited to attending occasional seminars on an ad hoc basis The inspector has a copy of the ANTR as well as appropriate ICAO manuals. A modest technical library is maintained by the International Relations Department. The library includes manuals for all essential aircraft types, but only a minimal assortment of industry information, publications and circulars The Flight Operations section is assisted in its certification and surveillance functions by twelve designated examiners who conduct flight checks for type ratings and proficiency checks. Initial and annual flight checks for all examiners is required. All examiner forms and procedures are specified in Procedures and Publications document P01/10 Designated Examiner, Flight Crew Personnel files and training records for inspectors are maintained in the section under two separate filing systems. The Human Resources office keeps records on personnel actions and career development plans. The ARL section keeps a single file that combines all other records for inspectors into one large file, making it difficult to review or retrieve specific documents. Appropriate security for the files is lacking. These files are presently not being reviewed in order to certify ongoing inspector qualifications The certification of new air operators is governed by established policy and procedures found in the Procedures and Publications document P01/06 Air Operator Certificates. Additional guidance for most certification job functions is included. However, requirements and procedures for the creation of a compliance document for the certification procedure, as well as guidance on the review and approval of aircraft leases, is missing.

10 The certification process is organized in six steps: application, preliminary assessment, operational inspection prior to certification, assessment, maintenance inspection, and final decision on the application. New certifications are handled by the Head of the ARL section and specialists from operations, airworthiness and personnel licensing are involved as necessary. Successful applicants are awarded an AOC which expires annually. A set of operations specifications are included with the certificate. Renewal criteria is the same as for original issuance. It should be noted that the entire certification process has been carried out only once in Bahrain, on the occasion of the certification of its single air operator The FOIG provides its inspectors with a series of handbooks for guidance in the conduct of their daily tasks. The handbooks, however, do not address the approval of aircraft leases, or the establishment of an annual surveillance programme. In practice, inspections are conducted on irregular basis or when requested by the industry. Any deficiencies identified during an inspection are handed informally. The inspector s Technical Procedures Manual states that inspections shall be accomplished in accordance with the requirements of ICAO Doc However, neither completed checklists for these inspections nor evidence that the minimum number of inspections had actually taken place, could be located during a review of the sole air operator s file Ongoing supervision of the handling of dangerous goods is accomplished by three trained technical personnel in the ARL section. The personnel are involved in the approval of dangerous goods training programmes, as well as in onsite inspections. Neither a copy of the approved dangerous goods programme nor any completed dangerous goods inspection checklists could be located in the file of the air operator Corrective action proposed/implemented by Bahrain In response to the recommendation that the CAA review and amend the ANTRs to ensure full compliance with the SARPs of Annex 6, the CAA indicated that it has implemented specific provisions such as ETOPS, flight and duty time limits and GPWS, with the introduction of Amendment No. 7 of the ANTR issued in December 2000 (articles 25 (para-4), 34A, 54, 55, 56, Schedules 4 and 11, and Annex D refer). In addition, a comprehensive review of all the regulations will be completed before 30 June In its action plan, the CAA indicated that it will hire at least two additional highly qualified and experienced operations inspectors by 30 June 2001 and will provide these individuals with remuneration comparable to their counterparts in industry. In addition, the CAA has arranged for the acquisition of permanent administrative support staff In accordance with the recommendation that the CAA amend the present certification system for air operators to require the submission of a compliance document, and also provide inspectors with comprehensive guidance to govern the approval of aircraft leases, the CAA indicated that it has implemented these provisions by revising the procedures ARL/OPS/01 Issue 2 of April 2001 and PO1/06 Revision 2 of May With regard to the recommendation that the CAA review and amend the present system of inspector guidance to include comprehensive CAA policy, procedures, and minimum acceptable standards for each air operator inspection, and to require the establishment of a written annual surveillance plan, the CAA indicated that this material will be prepared by the end of June The CAA noted that checklists are already being used for all required inspections.

11 In response to the recommendation that the CAA improve its filing system for technical personnel and air operators, including separate files for each inspector, an organized format to allow efficient retrieval of documents, periodic review of the files, and appropriate security, the CAA indicated that it has reviewed its filing system and implemented these recommendations. 3.6 Airworthiness of aircraft in Bahrain Abstract of findings Part III and most of the Schedules and the Annexes of the ANTR are the basis for the supervision and control of airworthiness activities in Bahrain. The inspector s Technical Policy Manual, and the Civil Aviation Law, supplement these airworthiness requirements. However, a detailed and comprehensive airworthiness code has not been developed. In addition, the absence of a type certificate validation policy raises questions concerning the legal basis of airworthiness certificates issued by Bahrain Regarding maintenance of continuous airworthiness, some of the regulations do not comply with ICAO SARPs, in particular, the approval of AMOS, Maintenance Programmes, AOCs, MELs and Reliability Programmes. Article 57 and Schedule 10 of the ANTR specify that a noise certificate is to be carried on board an aircraft but the CAA has not established standards and procedures for the issuance of such certificates. Additionally, there are no requirements for ETOPS operations The Airworthiness Inspection Group (AIG) has two inspectors, a Senior Airworthiness Inspector and an Airworthiness Inspector, which is a bare minimum for the level of aviation activity in Bahrain. The airworthiness oversight activities include issuance and renewal of Certificates of Airworthiness, facility approval, surveillance, and ramp checks on all aircraft operating into the country. The Airworthiness Group also performs maintenance engineer licensing duties. There is a serious lack of initial and recurrent training programmes for inspectors. Along with the other Groups in the Section, the AIG shares the support services of a secretary and an administrative clerk. The provision of laptop computers would facilitate airworthiness surveillance missions and make this very limited staff more effective and efficient. Additional vehicles are also required for local transportation The AIG has not established a formal surveillance programme, either for regular or random inspections. In practice, airworthiness surveillance is conducted once a year during the process of certificate of airworthiness renewal. There is a procedure and a checklist for conducting the inspection. The yearly surveillance applies to AMOs as well but, due to the small budget allocated to the task, surveillance of AMOs outside the country is not conducted on a regular basis Regarding the airworthiness approval requirements for AMOs, there are no guidelines or procedures for specialized maintenance activities, such as welding and NDT; there are no guidelines or procedures for assuring that AMOs employ qualified personnel; there are no procedures for controlling subcontracted maintenance work; AMO approval certificates do not contain capacity listings and limitations; and initial and recurrent training requirements for AMO personnel have not been developed With respect to maintenance schedule approvals, a structural integrity programme is not a requirement for an AOC holder s maintenance programme; reliability programme compliance is not a requirement for AOC holders; and the AIG does not participate in the development of ongoing analysis of reliability programmes.

12 Records from aircraft files are not easy to retrieve and are not complete. Most information and references are sought from the Operator/AMO as necessary. Records for items such as: time since new, airworthiness directive (AD) compliance summary, life controlled component status and time for programmed inspections are not available to the inspectorate. The AIG relies on manuals and documents maintained by the operator, making document compliance difficult to verify. There is no system to receive and adopt mandatory continuing airworthiness information such as Airworthiness Directives and Service Bulletins for the type of aircraft registered in Bahrain. There is lack of ongoing surveillance There is no aircraft engineering/manufacturing activity in Bahrain Corrective action proposed/implemented by Bahrain With respect to the recommendation that the CAA establish requirements and procedures for the issuance of noise certificates consistent with the SARPs of Annex 16, Vol. 1, including the initial issuance and/or the validation of noise certificates issued by another State, the CAA indicated that it will issue procedures for noise certification by 30 June Article 6A of Amendment No. 7 of the ANTR issued in December 2000, provides for the issuance of the noise certificate In accordance with the recommendation that the CAA establish a comprehensive and detailed national airworthiness code, develop a procedure for the validation of type certificates issued by other States, and ensure that the airworthiness code is entered on certificates of airworthiness issued by Bahrain, the CAA indicated that it has already implemented this recommendation In its action plan, the CAA indicated that it has established a technical library to ensure that all essential airworthiness information is made available to technical staff. A technical librarian will be employed by 30 June 2001 to manage the control, distribution, subscription, and amendment of all technical documents and reference materials With respect to the recommendation that the CAA establish a system and procedure for the receipt, adoption, and implementation of mandatory continuing airworthiness information for aircraft registered in Bahrain, the CAA indicated that it has revised Article 6 of the ANTRs and issued a procedure ARL/AW/030 Issue 1 of April 2001 in order to implement this recommendation With regard to the recommendation that the CAA implement all of the requirements for AMOs in accordance with the ICAO SARPs and associated guidance material, including procedures for specialized maintenance activities and subcontracted maintenance work, the CAA indicated that it has implemented this recommendation by issuing a Civil Aviation Notice, revising Annex B to the ANTRs (AMD 07/December 2000) and revising the procedure ARL/AW/05 Issue 3 of April Inspector training for specialized maintenance activities will be arranged by 31 December With respect to ensuring that aircraft records are complete and well-organized, in order to determine compliance with continuing airworthiness requirements as outlined in ICAO Doc. 9389, Chapter 6, the CAA indicated that this recommendation has already been implemented With respect to the recommendation that the CAA establish ETOPs requirements in the ANTRs in accordance with ICAO SARPs and develop associated procedures to ensure the participation of the airworthiness unit in ETOPs approvals, the CAA indicated that it has implemented these requirements by revising Article 34A and Schedule 11 of the ANTRs (AMD 07/December 2000).

13 In its action plan, the CAA indicated that it has now established a formal and comprehensive airworthiness surveillance program for air operators In response to the recommendation that the CAA establish requirements for the inclusion of structural integrity programmes in maintenance programmes, and require approval of reliability programmes for aircraft engaged in public air transport operations, the CAA indicated that it will develop appropriate regulations and procedures by 30 June The airworthiness group will receive appropriate training and begin to participate in the development and ongoing analysis of reliability programmes before 30 June COMMENTS As indicated above, Bahrain submitted an action plan on 18 December 2000, addressing all the findings and recommendations that were forwarded in the audit interim report. Further updates on the implementation of the action plan and on the list of differences from ICAO SARPs were submitted on 24 January 2001, 20 March 2001, 7 May 2001 and 26 May An attempt has been made in this report to reflect the action plan proposed by Bahrain along with the comments and feedback which were provided on the interim report. 5. STATUS OF IMPLEMENTATION AND DIFFERENCES FROM ICAO SARPs Differences existing between the national regulations and ICAO SARPs and/or SARPs not implemented that were confirmed at the time of the audit are contained in Appendices 6 and 7 of the interim report forwarded to Bahrain on 15 September On 7 May 2001, Bahrain submitted an update on its status of implementation and list of differences from ICAO SARPs which indicated that all differences identified during the audit have now been eliminated.

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