AUDIT SUMMARY REPORT OF THE CIVIL AVIATION AUTHORITY GREECE

Transcription

1 ICAO Universal Safety Oversight Audit Programme AUDIT SUMMARY REPORT OF THE CIVIL AVIATION AUTHORITY OF GREECE (Athens, 14 to 22 February 2000) INTERNATIONAL CIVIL AVIATION ORGANIZATION

2 ICAO UNIVERSAL SAFETY OVERSIGHT AUDIT PROGRAMME Audit Summary Report on the Safety Oversight Audit Mission to Greece (Athens, 14 to 22 February 2000) 1. BACKGROUND 1.1 The Civil Aviation Authority of Greece (Hellenic Civil Aviation Authority HCAA) was audited from 14 to 22 February 2000 by an ICAO safety oversight audit team in accordance with the Memorandum of Understanding (MOU) agreed on 2 November 1999 between Greece and ICAO and included in Attachment A to the audit interim report forwarded to Greece on 24 March The audit was carried out pursuant to Assembly Resolution A32-11, with the objective of ascertaining the safety oversight capability of the CAA of Greece 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 4 May 2000, Greece submitted an action plan addressing all the findings and recommendations contained in the audit interim report. The action plan submitted was reviewed by the Safety Oversight Audit (SOA) Section and was found to be satisfactory. On 25 August 2000, ICAO received additional comments on the final report. These comments and feedback submitted have been considered in the preparation of this audit summary report. 2. CIVIL AVIATION ACTIVITIES IN GREECE At the time of the audit, the civil aviation activities in Greece included: a) number of technical staff employed by the organization at Headquarters 24 b) number of active pilot licences c) number of active flight crew licences other than pilot licences 356 d) number of active licences other than flight crew licences e) number of commercial air transport operators 24 f) number of air operator certificates (AOCs) issued 24 g) number of aircraft operations inspectors 7 h) number of aircraft registered in Greece 424 i) number of Certificates of Airworthiness (C of A) issued 177 j) number of approved maintenance organizations (AMOs) 21 k) number of aircraft airworthiness inspectors 8

3 -2-3. SUMMARY OF FINDINGS 3.1 General statement The Hellenic Republic had established an aviation legislative system since it adhered to the Convention on International Civil Aviation but did not establish a procedure to update its civil aviation regulations to keep pace with the ICAO SARPs. The HCAA s ability to provide competent oversight of Hellenic operators is inhibited by an insufficient number of qualified inspectors and by the fact that they are not provided with an inspection credential allowing unlimited access to operators and other civil aviation organization facilities as may be required in the performance of their safety oversight duties The HCAA, which is part of the Greek Ministry of Transport and Communications, has operational responsibility for the certification and surveillance of civil aviation activities. It had eighteen fulltime inspectorate staff members at its Headquarters in Athens. The HCAA shared certification and safety oversight activities with the Aircraft Flight Inspection Inspectorate of the Ministry of Transport and Communications. The Inspectorate of the Ministry of Transport and Communications was largely responsible for the enforcement of the Greek and limited auditing of Greece s air operators. The HCAA, due to inflexible civil service requirements and low pay in comparison to the private industry in Greece, was unable to recruit the required number of qualified inspectors. The HCAA lacked the appropriate authority, legal credential, adequately qualified personnel, appropriate resources and equipment to effectively perform its inspection and surveillance duties A comprehensive system of personnel licensing has been established and JAR-FCL requirements are expected to be fully implemented by the end of The licensing system established is adequate and has experienced personnel licensing staff who, as a result of their experience, are capable of managing a satisfactory personnel licensing system. However, there are no written procedures for performing these duties. The duties and responsibilities of the licensing section including its relationship with other sections need to be clearly defined The Aircraft Flight Operations Section was supported by a range of legal instruments that have not kept pace with the ICAO SARPs nor the modern aviation environment. Operations regulations are no longer being updated due to the pending move to the Joint Aviation Regulations, JAR-OPS-1. The section had produced a new handbook of inspector procedures for the certification and surveillance of air operators, but implementation was difficult because the section suffers from an acute shortage of qualified personnel. Efforts to recruit and train additional inspectors were hampered by the requirements of the civil service system. The section also suffered from the lack of a proper inspector credential, a technical library and administrative support personnel The Airworthiness Department was poorly equipped and lacked the regulatory and information system tools that would enable it to meet its regulatory responsibilities. Airworthiness personnel were not provided with required training to keep pace with the industry and was significantly undermanned. Continuing airworthiness surveillance and oversight of commercial air transport operators, domestic operators and AMOs were not adequate. An airworthiness system for the certification and surveillance of international commercial air transport operators, which generally conforms with the requirements of Annex 6, Parts I and III, has not been effectively established. Largely due to the lack of appropriate national airworthiness

4 -3- regulations, corresponding procedures and a comprehensive technical library, there were large gaps in the implementation and control of airworthiness activities. 3.2 Primary aviation legislation and civil aviation regulations in Greece Abstract of findings The State primary aviation legislation in the Hellenic Republic is the Presidential Law No. 1815/88 Code of Aviation Law, enacted in 1988, to replace the previous Code. The provisions of the Code of Aviation Law are binding to all civil aviation activity within the Hellenic territory and also to Hellenic registered aircraft outside of the Greece flight information region (FIR). The legislative power rests with the Parliament and the President of the Republic who, by a Presidential Decree, issues the laws and their amendments following promulgation by the Parliament. Hellenic laws and regulations include the constitution, the laws, the presidential decrees, the regulations and the Governor decisions. Much of the Hellenic legislation addressing civil aviation was established in the 1960's and 1970's and has not been amended since to keep pace with the amendments made to the provisions of the ICAO Annexes. The legislation is established at different legislative levels by laws, royal decrees, presidential decrees, regulations and Governor s decisions The Hellenic civil aviation legislation is based on international standards, the provisions of the Chicago Convention and its Annexes and European legislation (European regulations and directives, JARs in different areas and ECAC recommendations). The Hellenic Republic, as a member of the European Union (EU), has to adopt the EU legislation which supersedes the national law. The European regulations are directly binding on EU member States and are not required to be transposed into the national legislation. There is an established process for the amendment of the national aviation legislation. Several articles of the Code of Aviation Law and related regulations make provisions for the establishment and publication of air navigation regulations addressing various aspects of civil aviation. Furthermore, Legislation Decree No. L 714/82, which established the structure of the HCAA, empowers the Governor to develop, issue and revise operating regulations by decisions or directives According to the Code of Aviation Law, the enforcement of the Hellenic civil aviation legislation may be accomplished by an administrative sanction or a criminal sanction. The administrative sanctions are undertaken by the Governor of the HCAA or by the Minister for the circumstances described in Articles 151, 152 and 153 of Chapter 19 of the Code of Aviation Law. Chapter 21 contains the criminal provisions of the Code. Article 158 of this chapter defines the territorial limits of these provisions and the conditions of applicability of the Greek regulations of Greece There is no established procedure for the amendment of the civil aviation regulations but according to common practice, amendments are initiated by the HCAA and follow the same channelling as a new legislation. The HCAA has the responsibility to prepare amendments to the national legislation and to submit them to the Ministry of Transport and Communications for adoption by the Government. The legal adviser of the Ministry and the Government Council legal adviser have the responsibility for the coordination and preparation of the legal aspect and for the submission of the amendments to the Government Council for adoption During the audit, four findings relating to the primary aviation legislation and civil aviation regulations were made and four recommendations put forward to rectify them.

5 Corrective action plan proposed/implemented by Greece With respect to the recommendation requiring Greece to achieve the highest practicable degree of harmonization of its civil aviation legislative framework with the ICAO SARPs to fulfill its international obligations regarding the Chicago Convention, the HCAA indicated that the whole spectrum of existing legislation is under reconsideration and updating through the help of legal consultants and that the Hellenic Republic will implement JAR-OPS as the regulation applicable to all HCAA AOC holders as of 31 July 2000 with an official transition period from 31 July 2000 to 31 July An interim revised version of the continuing airworthiness and personnel licensing regulations containing all current Annexes 1, 6 (Chapters 8 and 11) and 8 provisions will be published by 31 January The HCAA will, by 15 September 2000, establish a Legal Coordination Section within the Flight Standards Department for ensuring that proposed ICAO SARPs are reviewed and that proper action is taken following the adoption of new SARPs. The HCAA also indicated that, upon completion of the updating of the HCAA regulations expected to be completed by 31 January 2001, it will notify ICAO of any differences which may exist between its revised regulations and relevant Annex SARPs Concerning the need to amend the regulations to provide for the proper empowerment of the Inspectorate staff, the HCAA indicated that, by 31 July 2000, it will develop and publish in the Gazette the required authority for unrestricted access and the authority to inspect aviation activities in Greece unhindered. Appropriate credentials will also be issued to all qualified inspectors at the same time With regard to the need to amend the regulations to include provisions for the transportation of dangerous goods by air, the HCAA indicated that the Hellenic Republic will implement JAR-OPS-1, which also includes regulations for the transport of dangerous goods compatible to those provided by ICAO, as the regulations applicable to all HCAA AOC holders. JAR-OPS-1 is expected to be published in the Gazette on or around 31 July Civil aviation organization system in Greece Abstract of findings The principal government body responsible for civil aviation activities in Greece is the Hellenic Civil Aviation Authority (HCAA). The HCAA is part of the Air Transport Division of the Ministry of Transport and is headed by a Governor. The HCAA does not have regional offices responsible for safety oversight. Regional services consist primarily of airport offices which provide oversight of airport activities and aerodromes The HCAA has a delegated authority from the Ministry, for the oversight of civil aviation safety. The HCAA has six departments responsible for 424 aircraft on the registry of Greece, nine international commercial air operators, fifteen domestic air operators and twenty-one AMOs. The overall organization of the HCAA was not adequate to provide an efficient operational control and supervision capable of assuring the fulfilment of the State s safety oversight responsibilities. Key areas of concern included problems associated with the recruitment of personnel, remuneration of the inspectorate staff and the provision of training to the HCAA staff.

6 During the audit, eight findings relating to the civil aviation organization were made and eight recommendations put forward to rectify them Corrective action plan proposed/implemented by Greece With respect to the recommendation requiring Greece to increase the number of appropriately qualified and experienced inspectors, the HCAA indicated that, by 30 July 2000, it will provide the FSD with full-time inspecting officers to administer the AOC certification and surveillance tasks, full-time pilot-qualified inspectors, additional airworthiness inspectors (in addition to the four avionics inspectors assigned in March 2000) and will also contract the services of qualified Inspectorate staff to ensure that the FSD becomes an effective department. Additionally, the HCAA has requested the ICAO Cooperation Bureau to provide it, by 30 June 2000, with three operations and two airworthiness inspectors. The recruitment of these experts is under progress Concerning the need to amend the recruitment policy and streamline the recruitment process, the HCAA indicated that the Government will amend the policy by 30 September 2000 by changing the qualifications and experience requirements and adding a strong financial motivation to ensure that the HCAA be enabled to attract and retain the required personnel On the subject of issuing the Inspectorate staff with the required tools to effectively conduct their duties and responsibilities, the HCAA indicated that it has established a plan and the necessary resources to provide all FSD inspectors with the necessary guidance and reference material and technical library facilities by 30 June 2000, desktop computers by 31 December 2000, two vehicles for inspector duties by March 2000 and a local area network (LAN) system by 31 May With respect to the need for the HCAA to implement its own regulations and directives to develop a comprehensive training programme for HCAA inspectors, the HCAA indicated that the FSD has already contacted ICAO, the United Kingdom Civil Aviation Administration (CAA) and the Federal Aviation Administration (FAA) for scheduling training of its staff and has arranged for commencing the training of all its Inspectorate staff. It is in the process of developing a formal training plan for each specialty of inspectors expected to be ready by 31 July 2000 and also arrange for an ongoing on-the-job training for all inspectors throughout By 30 October 2000, the HCAA expects to have provided all its inspectors with formal indoctrination training on their responsibilities and technical job tasks On the subject of providing the FSD with adequate administrative assistance, clerical and secretarial support, the HCAA indicated that, on 1 March 2000, it has filled two new clerical positions and is undertaking an internal transfer for the required support and also to help maintain the FSD library and filing system. The HCAA also indicated that it will, by 31 July 2000, provide the FSD with adequate space, security and filing equipment and supplies to maintain their centralized files Concerning the need to provide an adequate budget allocation to the FSD for routine administrative expenditures granting them the flexibility to plan necessary travel for inspection and training purposes, the HCAA indicated that an unlimited budget exists for covering the needs of the FSD; however, it also indicated that it will, as of 30 August 2000, reserve an annual budget for the purpose of travel to meet the minimum required inspection and training requirements.

7 Personnel licensing and training system in Greece Abstract of findings The personnel licensing and training system is managed by the Diploma and Licences Section within the Flight Standards Division of the HCAA. The licensing system is also partially supported by the Civil Aviation Training Centre (HCAA Aviation Academy) which is subordinated to the HCAA Directorate General of Administrative Support and not the Director General of Air Transport. The Aviation Academy is responsible for the administration and conduct of written examinations for all aviation personnel licences. The Diploma and Licences Section is responsible for the flight and cabin crew licensing process beyond the theoretical examinations, such as the assessment of applications, the administration of practical tests and the renewal and validation of flight crew licences. In practice, all licences issued for the first time and all air traffic controller licences are signed by the Director of the HCAA Academy who is not part of the licensing authority. Licence renewals are signed by the Diploma and Licences Section technical officers The HCAA has not established detailed requirements and procedures for licensing examinations nor for the qualification and designation of examiners to enable its effective supervision and control of the entire examination process. Moreover, the Diploma and Licences Section does not have technical staff qualified as examiners and must rely on designated flight examiners from the industry. Aviation written examinations are conducted by the Aviation Academy without any formal co-ordination with the Diploma and Licences Section The medical assessment system is administered exclusively by the Military Aviation Medicine Centre. Regulatory medical requirements, concerning the medical assessment of civil aviation flight crews, are contained in Royal Decree No. 890/62. The Military Aviation Medicine Centre of Athens is authorized, under the provisions of Royal Decree No. 890/72, to undertake the medical checks for flight crew members. The HCAA has not established procedures for the designation of Aviation Medical Examiners. The HCAA does not designate individual aviation medical doctors or physicians experienced in the practice of aviation medicine. There are no established procedures in place for the evaluation of medical reports and they are not submitted to the Diploma and Licences Section. The HCAA did not establish appropriate action to be taken in the case of reported false medical declarations by applicants The HCAA validates foreign licences and issues its own licences on the basis of foreign licences. However, it has not established written procedures for tasks related to licensing approvals, such as the issuance of licences and ratings, the issuance of licences and ratings on the basis of foreign licences and the validation of foreign licences and ratings. The validity status of each individual licence is established by the Certificate of Validity (LVO) and, in the case of flight crew licences, by a Medical Certificate that is part of the flight crew licence The certification and supervision of training institutes and aviation schools are conducted by the HCAA Aircraft Flight Operations and Private Aviation Sections. Training schools based in Greece are inspected once every two or three years, without written standardized procedures. Aviation schools located abroad are not audited by the HCAA During the audit, five findings relating to personnel licensing and training were made and five recommendations put forward to rectify them.

8 3.4.2 Corrective action plan proposed/implemented by Greece With respect to the recommendation for the need to develop a personnel licensing procedures and guidance handbook, the HCAA indicated that part of such a handbook will be ready by 31 July 2000 and that, by 31 December 2000, it will have completed the consolidation of licensing procedures including procedures for the control and supervision of examinations into a single personnel licensing procedures and guidance handbook On the issue of the need to harmonize the licensing process, the HCAA indicated that the overall personnel licensing processes and procedures will be revamped and harmonized through a restructuring of the existing organization by 31 May On the subject of designating medical examiners, the HCAA indicated that under the existing Royal Decree No. 890/70, the Military Medical Aviation Centre of Athens is properly designated and is responsible for conducting medical examinations and evaluations and that all the doctors within the centre are well qualified and have experience in aviation medicine. It also indicated that, by 31 December 2000, in addition to the designation of the Military Medical Aviation Centre of Athens, it will publish aviation medical procedures for the designation of new aviation medical examiners, which will be included in the personnel licensing handbook. With respect of establishing the appropriate action to be taken in the case of reported false medical declarations by applicants, the HCAA has indicated there is such an established action; however, no reported false medical declarations were received by the HCAA the last few years Concerning the recommendation requiring the HCAA to develop clear and comprehensive procedures to establish the processes, control and supervision of all aviation licensing examinations and the designation and supervision of aviation examiners, the HCAA indicated that it will, by 31 October 2000, publish procedures for the appointment and supervision of airworthiness, operations and personnel licensing designees from the Greece aviation industry and that full evaluation of the existing regulations and procedures will be accomplished With regard to the recommendation concerning the control and supervision of aviation training institutes, the HCAA indicated that, by 31 July 2000, it will have in place procedures for the certification and supervision of approved training organizations. The procedures to be established will address the certification and supervision requirements for all types of training organizations approved by the HCAA. 3.5 Aircraft operations certification and supervision in Greece Abstract of findings The Aircraft Flight Operations Section is responsible for both the certification and the supervision of air operators in Greece. This section suffers from an acute shortage of qualified personnel. Until June 1999, the entire section was staffed by one person who subsequently retired in December The section is now composed of seven personnel who all joined the section within the last nine months. The section has no clerical or support staff. All personnel are responsible for their own clerical tasks, including the lengthy administrative procedures required for out-of-town travel.

9 Inspections outside the Aircraft Flight Operations Section is performed by two hundred and eighty-nine flight operations officers permanently stationed at the various airports throughout Greece and reporting to the Airports Division. These officers perform occasional ground inspections and checks that are traditionally accomplished by operations inspectors from the Aircraft Flight Operations Section. Inspections performed by the Airports Division officers include ramp checks, dispatch records inspections, dangerous goods inspections, refuelling operations, ramp safety and passenger security inspections. Inspection reports prepared by these officers are not normally made available to the Aircraft Flight Operations Section. The Operations Section is notified only when significant deficiencies are found In April 1999, the HCAA contracted with the United Kingdom for two qualified operations inspectors to provide check pilot services for Olympic Airways and some basic training for HCAA inspectors. One of the United Kingdom inspectors is normally in Greece for approximately a week in a month. In October 1999, the HCAA further contracted the services of the MITRE Corporation for three individuals to provide expertise in the development of the HCAA. Two of these individuals are qualified operations inspectors who have been in Greece since November 1999, during which time they have developed the Aviation Safety Inspector, Policy and Procedures Manual, Air Operator Certificate Administration. This document serves in a multi-functional role as operations policy and inspectors handbook. Although the contracts with the United Kingdom and MITRE Corporation will expire in June of 2000, both contracts contain continuation clauses for an extension. Comprehensive on-the-job training is provided by the MITRE Corporation consultants In the 1970s, when Olympic Airways was essentially the only airline in Greece, the Aircraft Flight Operations Section adopted a passive system for the certification of air operators. As a result, new operators were automatically granted certification, virtually upon request, after submission of a set of basic documents. There was no requirement for any actual inspection or operational proving prior to the issuance of an AOC. Upon certification a new air operator was issued a letter of authorization signed by the Governor and an attached list of technical specifications. These technical specifications are in letter format and function as operations specifications. As of 1 February 2000, the certification of new operators in Greece has been accomplished under the guidance of the newly developed Aviation Safety Inspector, Policy and Procedures Manual, Air Operator Certificate Administration. This manual generally conforms to the conventional five-step method of air operator certification contained in ICAO Doc The new manual also requires the issuance of an AOC to all air operators but does not establish a system for the issuance of technical specifications The ongoing supervision of air operators is accomplished by the Aircraft Flight Operations Section using the same cadre of inspectors as outlined above. The system is hampered by the fact that inspectors are not issued any type of official credential. They receive only an identification card which does not give them unrestricted access to companies or cockpits. The present policy requires that an inspector obtain a written approval form signed by the Director of Flight Standards or above, prior to conducting any inspection. Certificate holders expect to see this letter before submitting to an inspection. In the present practice, an inspector s place is considered to be within the HCAA Headquarters building Until recently, there was no formal schedule of inspections nor any required work programme established for the ongoing surveillance of certificated air operators in Greece. Inspections were accomplished only on demand or in response to some precipitating event. On 1 February 2000, the Aircraft Flight Operations Section implemented the new Aviation Safety Inspector, Policy and Procedures Manual, Air Operator Certificate Administration. The manual mandates a system of periodic inspections for air operators that generally complies with ICAO Doc 8335 One notable departure is that the new guidance requires only one base inspection per year instead of the two inspections recommended.

10 AOCs in Greece are issued without an expiration date, remaining valid as long as the company remains in compliance with the regulations. Deficiencies noted during inspections are addressed by enforcement provisions contained in the Code of Aviation Law. The Code of Aviation Law prescribes sanctions for violations including civil penalties, certificate suspensions and revocations. Specific enforcement procedures are provided in the new Policy and Procedures Manual. Two recent examples of certificate revocations were available for review. The approval of company check pilots is accomplished upon application by an air operator. The process involves only a review of Order No to ensure that the candidate meets the minimum qualifications. No flight check is conducted. There is no record-keeping system to track check pilot approvals During the audit, four findings relating to aircraft operations certification and supervision were made and four recommendations put forward to rectify them Corrective action plan proposed/implemented by Greece With respect to the recommendation on the need to amend the regulations to include all Annex 6 provisions, the HCAA, as mentioned above, indicated that it will, as of 31 July 2000, implement JAR-OPS-1 as the national regulations for the certification and supervision of operators Concerning the staffing of the Operations Inspectorate with an adequate number of qualified and experienced inspectors, the HCAA will provide the FSD, by 30 July 2000, with full-time inspecting officers to administer the AOC certification and surveillance tasks and full-time pilot-qualified inspectors to conduct aircraft specific certification, crew licensing and inspection tasks. Proposed action on staffing level in all the departments of the FSD has been addressed above With regard to the need to amend the air operator certification policies and procedures to be in conformance with the requirements of Annex 6, the HCAA indicated that it has revised in March 2000 its Air Operator Certificate Administration and Supervision ASI Guidance Manual to comply with Annex 6 requirements. As of June 2000, the HCAA has been issuing new AOCs to all Greek operators authorized to conduct commercial air transport operations based on the JAA format On the issue of the need to establish a comprehensive system to address approved specific operations such as CAT II, CAT III, ETOPS, RVSM, RNP, MNPS, etc., the HCAA indicated that, by 31 July 2000, it will edit the Air Operator Certificate Administration Manual to include more specific certification guidance on all the specifications raised by ICAO. The adoption of the JAR-OPS-1 on 31 July 2000 will also assist in resolving these concerns. 3.6 Airworthiness of aircraft in Greece Abstract of findings The airworthiness duties of controlling and supervising airworthiness activities in Greece are centralized at the HCAA Headquarters office in Athens. There are no regional offices and airworthiness activities are primarily located at the Athens airport. Initial and recurrent training is a problem in the Aircraft Airworthiness Section as funding is not available for this training and the Flight Standards Division has not established a formal training programme for aircraft or specialized systems training. The Aircraft Airworthiness Section has started developing an inspectors guidance handbook which mainly focuses on the certification of air operators. The high volume of aviation activity and the limited staff available to the

11 -10- Aircraft Airworthiness Section result in an ineffective oversight capability and a need for immediate recruitment of inspectors in the Aircraft Airworthiness Section The Aircraft Airworthiness Section is using the requirements of JAR-145 for the approval of maintenance organizations in Greece. However, requirements for the escalation of maintenance programmes and for international air operators to generate and submit their reliability programmes to the Flight Standards Division have not been established. Additionally, there is a need for greater involvement on the part of the Aircraft Airworthiness Section in surveillance and supervision of its international air operators The Aircraft Airworthiness Section is responsible for 424 aircraft on the aircraft registry of Greece, nine international commercial AOCs, fifteen domestic air operators and twenty-one AMOs. In addition to these, there are two certified AME training schools, aircraft maintenance engineer licences and one aircraft parts manufacturer working under licence. There are also several major repair establishments in Greece outside of Athens and over seventy-five foreign air carriers transiting Greece s airspace at any given time. Additional complexity arises from the diversity of the aircraft registry, which includes Boeing 747, Boeing 717, Boeing 727, Boeing 737 and Airbus 340, all of which are involved in international service. Domestic aircraft include ATR-72, De Havilland DHC-7 and Fokker 100's. In addition to these, there is an expansive list of helicopters which fly internationally and a varied fleet of general and corporate aviation aircraft Greece has adopted, as national codes for the manufacturing of aircraft, the relevant JAA codes: JAR-23, JAR-25, JAR-27, JAR-29, etc. As a member of JAA, Greece receives all amendments to the codes and participates in the process of their issue and modification During the audit, fifteen findings relating to airworthiness of aircraft were made and fifteen recommendations put forward to rectify them Corrective action plan proposed/implemented by Greece With respect to the need to develop requirements and procedures for the designation, control and supervision of designated airworthiness inspectors, the HCAA indicated that it will publish the required procedures by 30 November On the issue that the HCAA should develop effective procedures for the validation of type certificates issued by another State, the importation of aeronautical products, the approval of major modifications and repairs and the dissemination of such information, the HCAA indicated that it will develop and publish the required procedures by 30 November 2000 in a single manual for airworthiness approvals. The manual will include all the issues and concerns raised by ICAO. On the subject of the provision of information concerning a least risk bomb location, the HCAA will request all operators to amend their Aircraft Flight Manual to address the requirement by 31 July Concerning the establishment of policies, procedures and methodology, as applicable: to monitor mandatory continuing airworthiness information (ADs) from States of Design and to ensure compliance through periodic surveillance; for systems difficulty reporting; to maintain copies of the Maintenance Control Manuals and Maintenance Procedures Manual; for procedures on the approval of MELs; to require that all navigation equipment requiring specific airworthiness approval and quality control be accomplished as outlined in ICAO guidance; and to ensure that inspectors check the aircraft limitations and appropriate airworthiness requirements in the Aircraft Flight Manual when a Certificate of Airworthiness is renewed, the HCAA indicated that it will develop the applicable policies, procedures and methodology and include them in the Air Operator Certificate Administration Manual by 31 July 2000.

12 With regard to the need to amend the regulations to establish a requirement for operators to submit aircraft maintenance reliability information, the HCAA indicated that the Hellenic Republic would require, by 30 April 2000, all international air operators to provide the HCAA with aircraft reliability information as required by Law No. 22/64 and JAR-OPS-1. On the issue of the need to ensure that national regulations and instructions are implemented and on the need to require air operators to undergo re-certification prior to adding any new aircraft types to their certificates as required in the Safety Inspector Guides, the HCAA indicated that it will continue its initiative to review the previous certification of all Greek AOC holders through document evaluation and heightened inspection activities. This will be an ongoing process which had started in December 1999 and will continue during the JAR-OPS implementation period until July Concerning the need for the HCAA and its Airworthiness Section to follow their own guidelines concerning the adoption of a valid surveillance and inspection programme and to enforce the rules governing the reporting of faults, defects and malfunctions, the HCAA indicated that it will ensure that its inspectors comply with established guidelines and, on the issue of enforcement, it would require operators to comply with Order No. 7-1 by 1 May With respect to the need for the Government to amend the regulations to adopt a national standard on the initial and continuation training and certification of aircraft welders and the establishment of the HCAA oversight to ensure that test piece certification and material specification qualification are carefully followed to guarantee the integrity of the certification process, the HCAA indicated that the Hellenic Republic will, by 31 December 2000, establish and publish national standards for the initial and continuous training and certification of aircraft welders With reference to the need for the Government to amend the regulations to ensure that maintenance programmes include a continuing structural integrity programme and procedures for maintenance programme escalation, the HCAA indicated that it will, by 31 July 2000, establish procedures to ensure that the operators maintenance programme includes a continuing structural integrity and escalation programme and will approve them prior to implementation. Those procedures will also be included in the Airworthiness Procedures Manual. 4. COMMENTS 4.1 As indicated above, the proposed corrective action plan of Greece addressed all the recommendations and safety concerns raised by ICAO. The HCAA has also approached the assistance of ICAO through the Cooperation Bureau to help it resolve the safety concerns raised. The effort being made confirms the commitment of Greece and its Civil Aviation Authority to safety in aviation. 4.2 Several of the actions proposed were scheduled to be completed by 31 July 2000 and several others should be in progress in order to be completed by the scheduled dates within this year. Therefore, the HCAA is requested to provide the ICAO Safety Oversight Audit Section at ICAO Headquarters with information on the progress of actions completed and the status of implementation of those which are in progress.

13 STATUS OF IMPLEMENTATION AND DIFFERENCES FROM THE ICAO SARPS Differences vis-à-vis Standards which were identified during the audit are found in the Appendix to this summary report and will be included in the relevant Annex supplement in line with Article 17 of the MOU signed between Greece and ICAO.

14 APPENDIX STATUS OF IMPLEMENTATION AND LIST OF DIFFERENCES FROM THE ICAO STANDARDS (ANNEX 6 OPERATION OF AIRCRAFT) (PART I International Commercial Air Transport Aeroplanes) ICAO Standard reference Chapter 8 State s regulations reference HCAA Differences between the national regulations of Greece and ICAO Standards Not all the requirements contained in Chapter 8 concerning the operator s maintenance organization s procedure manual, operator s maintenance control manual, maintenance programme, maintenance records and continuing airworthiness information are referred to in the Hellenic CAA. Partially implemented HCAA Hellenic civil aviation regulations do not require records to be maintained after the end of the operating life of the unit. Chapter HCAA Requirements contained in Chapter 11 concerning the operator s maintenance control manual, subcontractor control and audit, maintenance records, continuing airworthiness information and approved maintenance organizations are not referred to in the Hellenic civil aviation regulations. Partially implemented.

15 -2- STATUS OF IMPLEMENTATION AND LIST OF DIFFERENCES FROM THE ICAO STANDARDS (ANNEX 6 OPERATION OF AIRCRAFT) (PART III International Operations Helicopters) ICAO Standard reference Chapter 6 State s regulations reference Differences between the national regulations of Greece and ICAO Standards N/A Hellenic CAA regulations do not require that the design and application of the maintenance manual observe human factors principles. 6.3 N/A There is no comparable requirement in the HCAA regulations for training in knowledge and skills related to human performance N/A There is no HCAA requirement for operator s maintenance records to be kept for a period of 90 days after the end of the operating life of the unit to which they refer. Chapter N/A Greece does not require that helicopter journey logbooks contain all of the requirements listed in N/A Helicopter journey logbook entries are not required to be entered in ink or indelible pencil.

16 -3- STATUS OF IMPLEMENTATION AND LIST OF DIFFERENCES FROM THE ICAO STANDARDS (ANNEX 8 AIRWORTHINESS OF AIRCRAFT) ICAO Standard reference Part II State s regulations reference Differences between the national regulations of Greece and ICAO Standards HCAA The Hellenic CAA does not always inform the State of Design when it enters a specific type for which it is not the State of Design on its aircraft register. Not implemented and Part III HCAA In the case of damage to an aircraft and permission given by the State or Registry for ferry flight, the HCAA provides that the HCAA Flight Standards will not permit a flight if it considers that it would be detrimental to the safety of air navigation. Not implemented HCAA HCAA HCAA The Hellenic CAA rule incorporates the FAA requirement for service experience and equivalent safety findings to be used as a basis for finding compliance with the appropriate airworthiness requirements. Not implemented. The ICAO provision requires performance data to be scheduled for ranges of gradient of the landing surface for landplanes and ranges of water surface conditions, water density and current strength for sea planes. For land planes, it requires the landing distance to be determined only on a level runway. For seaplanes, it requires the landing distance on water to be determined only on smooth water. Not implemented. Stall warning and recovery enables the pilot to arrest the development of the stall rather than stopping the action before it occurs. Hellenic CAA rules regarding stall warning do not explicitly refer to alarms with one power-unit inoperative. Not implemented N/A There is no provision in the HCAA rules for aircraft least risk bomb location identification. Not implemented HCAA Markings and placards or instructions to be provided to ground crew in order to prevent the possibility of mistakes in ground servicing, which could go unnoticed and which could jeopardize safety of the aircraft in subsequent flights, are not covered in the CAA rules of Greece. Not implemented. END