By Dr Moses Amweelo
THE regulatory framework and safety oversight activities are carried out by the Directorate of Civil Aviation (DCA) in accordance with the Civil Aviation Act, 1962 (Act No. 74 of 1962), and civil aviation regulations, which came into operation on March 2, 2001.
The basic purpose of the Civil Aviation Act is to control and manage civil aviation. The Act empowered the Government to frame rules and provided the legal framework for enforcement.
The civil aviation regulations are complemented by a series of requirements established by the Directorate of Civil Aviation. The requirements applicable to safety oversight activities include the inspection requirements, airworthiness requirements, flight operations requirements, the air operator certificate requirements, etc. According to the Namibian civil aviation regulations, 2001 Part 43, subpart 43.02.10 any person who carries out an inspection shall:
– Carry out the inspection so as to determine that the aircraft or aircraft component under inspection, complies with all appropriate airworthiness requirements prescribed in Part 21; and
– If carrying out a mandatory periodic inspection, use a checklist, which includes the scope and detail of the tests and inspections referred to in regulation 43.02.6.
The person who carries out maintenance on an aircraft or aircraft component where the applicable maintenance data requires a non-destructive test as specified in document NAM-CATS-GMR, shall:
– Be a holder of a current certificate appropriate to the technique being used, or an equivalent certificate approved by the director; and
– Perform the non-destructive test using appropriate methods, techniques and practices approved by the director.
– Be a holder of a valid eye test certificate.
Inspections/Surveillance of Aircraft Operations
The activities for the surveillance of flight operations include ramp inspections, audits and observation of initial pilot proficiency flight tests and type ratings. The surveillance plan includes each operator and provides a schedule of audits to be performed during the year. The inspectors use checklists whenever they are conducting audits and ramp inspections.
According to civil aviation regulations 2001, the person who carries out maintenance on an aircraft or aircraft component shall record, on completion of the maintenance. The purpose and benefits of a good record-keeping system can be summarised as follows:
– Details of the maintenance including, where applicable, the type of inspection and any approved data used;
– For a progressive inspection, whether a detailed inspection or routine inspection of the particular components or areas of the aircraft was carried out;
– The serial numbers, if any, of components removed or fitted;
– Details of measurements or test results obtained, including the results of any ground or air tests;
– For an altimeter system test and inspection, the date on which and maximum altitude to which the altimeter has been tested;
– The date of completion of such maintenance;
– The name of the person completing such maintenance, if other than the person certifying the release to service;
– The location and, if applicable, the name of the facility where such maintenance was carried out; and
– Where such maintenance has been carried out as a consequence of the failure of any equipment, or damage caused by forced landing or accident, the reasons for carrying out the maintenance.
The Human Factor and Safety
The Directorate of Civil Aviation with its objective of enhancing safety and efficiency has also captured the essence of human factors, which read:
“Human factor is about people, it is about people in their working and living environment and efficiency and it is about their relationship with equipment, procedures and environment. Just as important, it is about their relationships with other people”. Analysis of incident and accident data reveals a large percentage attributable to human factor problems. Some of the crew errors which closely relate to human factors are:
– Loss of directional control
– Judgment error
– Poor pre-flight planning and decision-making
– Non-adherence to clearance
– Inadvertent stalls
On May 9, 2008 a Cessna 210, V5 LSO light aircraft crashed at the TransNamib Gammams Training Centre shortly after take-off from Eros Airport. Members of the fire brigade sprayed the area with foam to prevent an explosion (New Era May 12, 2008). Another aircraft (type registration and serial number, Cessna 210, V5-GWH), sustained major damage beyond repair, since it was destroyed by the fire after the crash on January 11, 2008.
In relation to the above-mentioned aircraft accidents, the DCA has laid emphasis on crew training and it is the requirement that human performance limitation including cockpit resource management (CRM) should be included in a training programme and should be covered once a year during recurrent training. The Directorate of Civil Aviation’s regulations and advisories have reflected some of the human factor standards, which have been based on proven principles, time-tested procedures, regulatory experience and available data. Besides setting standards, DCA also has conducted several workshops, seminars, conferences and studies on human performance in aviation. A seminar on aviation safety and controlled flight into terrain in February this year organised by DCA has been an important step in creating awareness and planning policies and implementation strategies.
Safety Issues in Civil Aviation
Key safety issues in civil aviation but not necessarily limited to:
– Lack of comprehensive safety oversight activities
– Lack of identification of shortcomings and deficiencies
– Lack of harmonisation of safety rules
– Potential for air traffic conflict and insufficient reporting system
– Tendency to import and operation of old aircraft and their life extension
– Lack of quality assurance and safety assurance
– Lack of corporate culture
– Less attention to the moral obligations, public expectations and economic benefits of safety
Every effort should be made to achieve the highest level of safety at all times. For instance, an aviation product, be it an aircraft in total or a fastener, it has to meet a stringent specification or requirements. The basic safety lies in laying down the requirements. Once the requirements are laid down, a strict translation of the requirements is essential in manufacturing the product. Once the product is manufactured to specification, it is marketed in the field. The responsibility of meeting the target of safety then lies in the hands of the operator and agency involved in maintaining the aircraft. Safety therefore does not depend on one or two individuals or agencies in isolation, rather it depends on all the units involved in different process, the designer, manufacturer and the operator. The role of the regulatory authority is to ensure that every unit is functioning as expected.
Safety Oversight: Critical Concerns and Priorities
In fulfilling the responsibility of the regulatory authority, the only tool available is to conduct regular, systematic and quality audits. In many of the developing countries, the constraints are mainly manpower to use the above-mentioned tool. Most of the regulatory bodies fail to retain their manpower because of the substantial difference in remuneration with the industry they control. Therefore, most of the state regulatory authorities are working with less than required manpower or below capacity. This has an adverse impact on the oversight capability. In spite of constraints of human resources the regulatory authorities are trying to meet their obligation and the findings definitely point at some common deficiencies. They include:
– Shortage of technical skilled manpower
– Lack of work culture
– Lack of dedicated safety training institute of quality standard.
– Lack of commitment from the operator in developing manpower and other infrastructure
– Lack of commitment from the operator to meet the law of the land.
– Lack of risk identification and management system.
– Lack of system safety concept for interactions among components (people procedure, equipment, materials, tools, software and facilities) within and between systems and sub-systems.
Therefore the responsibility and priority of the authority is to keep a vigilant eye to ensure that failures are identified and curbed before they become incorrigible. Some people believe and admit that often trying to comply with the requirements brings more brickbats than bouquets. However, commitment to our profession makes us move forward in spite of hurdles faced.
Issues and Problems Faced by States in Safety Oversight Implementation
As discussed earlier, the most prominent issue in state’s problem is adequate, qualified and experienced manpower to implement programmes. There is no doubt that even though the problems are identified, sometimes they cannot be addressed for the interest of the nation. Being away from the manufacturing countries often puts some burden on the operators of the region. Much of the valuable limited items are lost in transportation. Since the requirement of specialised services as demanded by aviation are very few, development of such facilities are often economically not viable. It has also been observed that infrastructure required to support a basic establishment, often costs a big chunk of resources.
– To be continued
. Aviation is a capital-intensive industry. No wonder that implementation may therefore be imposed with judgment, rather than being ruthless. Some of the problems observed by the Directorate of Civil Aviation (DCA) are but not necessarily limited to:
– Tendency among private airlines to acquire aircraft on lease purchase and tempted to have short-term benefit,
– Low investment in equipment, infrastructure and manpower development is a common symptom of almost all private airlines,
Direct initial investment to own rather than the lease option is less likely. However, some of the private airlines have acquired new aircraft under lease purchase arrangements.
Insufficient staffing level of operations and airworthiness to adequately implement the operations and airworthiness requirements.
Concentrated training for safety oversight responsibilities from a system approach is necessary for safety inspectors. Such training will improve safety oversight inspection and management.
Establishment of civil aviation safety academy approach for the enhancement of safety instructor training.
Harmonisation of civil aviation safety regulations, standards, procedures and associated processes employed in the manufacture, maintenance and operation of the civil aviation system should continue to be pursued.
A cooperative approach and collaborative effort should be undertaken with due regard ICAO (International Civil Aviation Organisation) initiative.
Safety Responsibilities of Industry and Regulatory Authority
All said and done the commitment to the commuting public cannot be denied both by the operator and the authority. A responsible operator will not only try to run the organisation economically, but will also ensure that all the requirements are met. If the operator abides by the rules and requirements, then operation can run smoothly without being halted by the authority for non-compliance.
Operator should understand typical need of operation and develop manpower, equipment etc to cater for the need. Training of crew for hazardous terrain flying or equipping aircraft with weather radar, etc may be an indication of operator’s maturity and commitment towards safety.
Operator should not feel that meeting the minimum requirements as laid down by the authority absolves him/her of all responsibility. In order to have a good track record, operator must be progressive and foresighted.
It should be borne in mind that expense on training is not wastage but an investment; and for sure this will pay back with interest. If you feel developing manpower is costly, imagine loss of a machine due to ignorance of either maintenance or operating crew. Therefore the operator has a very important role to play in achieving safety.
Responsibility also lies with the operator to have a continuous link with the manufacturer and the regulatory authority of the country of manufacture of the aircraft. This serves a dual purpose – one the manufacturer gets a continuous feedback from the operators and can make necessary modifications/improvements for better performance of the machine and the operator also gets to know about various changes that the manufacturer wants to comply with.
Since regulatory authorities are committed to the travelling public, both national and international, they have to take initiatives that will project foresight, pragmatic approach at the same time operator friendly.
Development of infrastructure, framing of detailed requirements, laying down clear policies, are all steps towards achieving safety. It is essential that the operators know their obligations and requirements to be met. The more transparent the policies, the less hassles there are for the operators and authority.
Safety cannot be achieved free of cost, it has a price tag. The essential factors are men, equipment and literature. It costs money to develop manpower, or acquire equipment and buy literature, but to achieve the targeted safety goal such investments are unavoidable. Investigation findings of many of the accidents reveal that there is more to it than meets the naked eye. In most of the cases, which, some time ago, used to be closed as human error on the part of the crew; if reviewed today with new knowledge of human factor, mostly will involve the management or the authority in terms of lack of training or lack of aids in performing the activity. Therefore it is essential that we do not close our eyes to the need of taking right and timely safety initiative.
Finally, actions required are manifold, both on the part of the authority and for the operator. On the one hand authority should provide basic infrastructure, better navigational and communication facility, better runways, etc. On the other hand the operator should understand the responsibility and operate maturely by developing manpower both in maintenance and flying crew, invest in getting the essential literature, using the right equipment and not take the stand that “Nothing will happen” or “Well, we have been doing it this way for the last so many years”. They should understand that “nothing” happened in the last so many years could be just by luck, and luck is not the scientific ingredient of safety.
If we have to attain a level of safety, to be proud of, all of us have to work for it. All of us have to put our efforts together to overcome the challenge.
Needless to say that discipline is an essential ingredient to achieve this goal.
The commitment towards safety should percolate down from the top management. If the top manager understands that an air-turn-back or a missed approach is not a loss rather it is a matter of joy that the aircraft is safe, then the crew will not be under pressure to take unnecessary chance and will be relaxed to take matured and right decisions.
Management should also take punitive action against those who break the laid down rules/policies. If the person committing the error is not curbed at the very beginning, he will become a hardcore error committee and one day will pay for mistakes but will also drown the organisational resources and reputation. Safety can be enhanced, where people are confident of their abilities, but knowledgeable about their limitations, and are able to recognise and admit there is always room for improvement.
ICAO should continue to play its leading role in providing technical cooperation and assistance to states to enhance safety. Cooperative initiatives should be continued with the active participation of the member and non-member states, donor governments and agencies.
Compliance to ICAO should be given the highest priority. Apart from enforcement of regulations, interactions between regulatory authorities and airline industry both at decision-making and operational level, within and between systems, sub-systems and elements should be a regular feature.
Each airline – domestic or international – should be effectively monitored and motivated to introduce safety and corporate culture, accident/incident prevention programme and safety systems and management within the organisation.