FINAL REPORT ON THE SAFETY OVERSIGHT AUDIT OF THE CIVIL ... · Final Safety Oversight Audit Report...

ICAO Universal Safety Oversight Audit Programme

FINAL REPORT ON THE SAFETY OVERSIGHT AUDIT

OF THE CIVIL AVIATION SYSTEM

OF GHANA

(20 to 28 November 2006)

International Civil Aviation Organization

Final Safety Oversight Audit Report ― Ghana August 2007

TABLE OF CONTENTS Page 1. INTRODUCTION.......................................................................................................................... 1

1.1 Background......................................................................................................................... 1 1.2 ICAO audit team composition ........................................................................................... 1 1.3 Acknowledgements............................................................................................................. 2

2. OBJECTIVES AND ACTIVITIES OF THE AUDIT MISSION .............................................. 2 3. AUDIT RESULTS ......................................................................................................................... 3

3.1 Critical element 1 — Primary aviation legislation.............................................................. 3 3.2 Critical element 2 — Specific operating regulations .......................................................... 4 3.3 Critical element 3 — State civil aviation system and safety oversight functions ............... 6 3.4 Critical element 4 — Technical personnel qualification and training ................................ 8 3.5 Critical element 5 — Technical guidance, tools and the provision of safety critical

information........................................................................................................................ 10 3.6 Critical element 6 — Licensing, certification, authorization and/or approval obligations11 3.7 Critical element 7 — Surveillance obligations ................................................................. 12 3.8 Critical element 8 — Resolution of safety concerns......................................................... 13

4. VISITS TO THE INDUSTRY/SERVICE PROVIDERS ......................................................... 14 5. AUDIT FINDINGS AND DIFFERENCES DATABASE (AFDD) .......................................... 15 6. STATE AVIATION ACTIVITY QUESTIONNAIRE (SAAQ)............................................... 15 7. COMPLIANCE CHECKLISTS (CCs) ...................................................................................... 15 8. FOLLOW-UP ACTION .............................................................................................................. 15 APPENDICES 1 — Audit findings and recommendations

1-1 Findings and recommendations related to primary aviation legislation and civil aviation regulations

1-2 Findings and recommendations related to civil aviation organization 1-3 Findings and recommendations related to personnel licensing and training 1-4 Findings and recommendations related to aircraft operations certification and

supervision 1-5 Findings and recommendations related to airworthiness of aircraft 1-6 Findings and recommendations related to aircraft accident and incident investigation 1-7 Findings and recommendations related to air navigation services 1-8 Findings and recommendations related to aerodromes

2 — Graphic representation of the lack of effective implementation of the critical elements 3 — Corrective action plan proposed by Ghana

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Final Safety Oversight Audit Report — Ghana August 2007

ICAO UNIVERSAL SAFETY OVERSIGHT AUDIT PROGRAMME

Final Report on the Safety Oversight Audit of the Civil Aviation System of Ghana

(20 to 28 November 2006)

1. INTRODUCTION 1.1 Background 1.1.1 The 32nd Session of the ICAO Assembly (Assembly Resolution A32-11 refers) resolved the establishment of the ICAO Universal Safety Oversight Audit Programme (USOAP), comprising regular, mandatory, systematic and harmonized safety audits of all Contracting States. The mandate for regular audits foresaw the continuation of the Programme, and the term “safety audits” suggested that all safety-related areas should be audited. The expansion of the Programme “at the appropriate time”, as recommended by the 1997 Directors General of Civil Aviation Conference on a Global Strategy for Safety Oversight, had thus been accepted as an integral part of the future of the Programme. 1.1.2 The 35th Session of the ICAO Assembly considered a proposal of the Council for the continuation and expansion of the USOAP as of 2005 and resolved that the Programme be expanded to cover all safety-related Annexes (Assembly Resolution A35-6 refers). The Assembly also requested the Secretary General to adopt a comprehensive systems approach for the conduct of safety oversight audits. 1.1.3 Assembly Resolution A35-6 further directed the Secretary General to ensure that the comprehensive systems approach maintain as core elements the safety provisions contained in Annex 1 ― Personnel Licensing, Annex 6 — Operation of Aircraft, Annex 8 — Airworthiness of Aircraft, Annex 11 ― Air Traffic Services, Annex 13 — Aircraft Accident and Incident Investigation and Annex 14 ― Aerodromes; to make all aspects of the auditing process visible to Contracting States; to make the final safety oversight audit reports available to all Contracting States; and also to provide access to all relevant information derived from the Audit Findings and Differences Database (AFDD) through the secure website of ICAO. 1.1.4 In accordance with Assembly Resolution A35-6, safety oversight audit reports have been restructured to reflect the critical elements of a safety oversight system, as presented in ICAO Doc 9734 ― Safety Oversight Manual, Part A — The Establishment and Management of a State’s Safety Oversight System. ICAO Contracting States, in their effort to establish and implement an effective safety oversight system, need to consider these critical elements. 1.2 ICAO audit team composition 1.2.1 The safety oversight audit team was composed of: Mr. Rennie van Zyl, team leader, primary aviation legislation (LEG)/civil aviation organization (ORG)/aircraft accident and incident investigation (AIG); Mr. Papa Issa Mbengue, team member, personnel licensing (PEL)/aircraft operations (OPS); Ms. Elizabeth Gnehm, team member, airworthiness of aircraft (AIR); Mr. Prosper Zo’o-Minto’o, team member, air navigation services (ANS); Mr. Jean-Claude Waffo, team member, aerodromes (AGA); and Mr. Leon Vonlanthen, team member, on-the-job training (OJT)/aircraft accident and incident investigation (AIG).

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1.3 Acknowledgements 1.3.1 ICAO expresses its sincere appreciation for the assistance provided to the audit team during the preparation and conduct of the audit. The professionalism and enthusiasm of all personnel who interacted with the audit team greatly contributed to the success of the audit mission. 2. OBJECTIVES AND ACTIVITIES OF THE AUDIT MISSION 2.1 The comprehensive systems approach for the conduct of safety oversight audits consists of three phases. In the first phase, the level of implementation of Annex provisions is assessed and differences from ICAO Standards and Recommended Practices (SARPs) are identified for each Contracting State through a review of a duly completed State Aviation Activity Questionnaire (SAAQ) and Compliance Checklists (CCs) for all safety-related Annexes, as well as through a review of documents developed by the State to assist it in implementing SARPs and in maintaining an effective safety oversight system. In the second phase, the State being audited is visited by an ICAO audit team to validate the information provided by the State and to conduct an on-site audit of the State’s overall capability for safety oversight. The third phase of the audit process consists of the activities following the completion of the on-site audit. 2.2 The safety oversight audit of Ghana was carried out from 20 to 28 November 2006 in accordance with the standard auditing procedures provided for in ICAO Doc 9735 — Safety Oversight Audit Manual and the Memorandum of Understanding (MOU) agreed to on 7 April 2005 between Ghana and ICAO. The audit was carried out with the objective of fulfilling the mandate given by the Assembly which requires ICAO to conduct a safety oversight audit of all Contracting States (Assembly Resolutions A32-11 and A35-6 refer), reviewing a State’s compliance with ICAO SARPs set out in all safety-related Annexes and their associated guidance material, as well as with related Procedures for Air Navigation Services (PANS). Furthermore, the objective was also to offer advice, as applicable, to Ghana in implementing these provisions. 2.3 The audit team reviewed the SAAQ and the CCs submitted by Ghana prior to the on-site audit in order to have a preliminary understanding of the civil aviation system established in the State, to determine its various functions as well as to assess the status of implementation of relevant Annex provisions. Information provided and assessed prior to the conduct of the audit was validated during the on-site audit phase. In this regard, particular attention was given to the presence of an adequate organization, processes, procedures and programmes established and maintained by Ghana to assist it in fulfilling its safety oversight obligations. 2.4 The audit results, including the findings and recommendations contained in this report, reflect the capabilities and limitations of the civil aviation system of Ghana as assessed by the audit team. They are thus based on evidence gathered during interviews conducted by the audit team with Ghana’s technical experts and background information provided by such personnel, review and analysis of civil aviation legislation, specific regulations, related documentation and file records. Considering the time that was available to conduct the audit and the fact that the safety oversight audit team members could only review and analyse information and documentation made available by the State, it is possible that some safety concerns may not have been identified during the audit. The findings and recommendations related to each audit area are found in Appendix 1 to this report.

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3. AUDIT RESULTS 3.1 Critical element 1 — Primary aviation legislation

“The provision of a comprehensive and effective aviation law consistent with the environment and complexity of the State’s aviation activity, and compliant with the requirements contained in the Convention on International Civil Aviation.”

3.1.1 The primary aviation legislation of Ghana is encapsulated in the Ghana Civil Aviation Act, 2004 (Act 678, hereinafter the “Act”), which was enacted by Parliament on 11 November 2004 and published in the Ghana Gazette No. 49 on 12 November 2004. The Act establishes the Ghana Civil Aviation Authority (GCAA) as a body corporate located in the city of Accra. The policy objectives and functions of the GCAA are specifically defined in Articles 2 and 3 of the Act. Article 4 of the Act also provides for the establishment of a Board which “is responsible for the formulation of general policies for the proper management of the affairs of the Authority, and for ensuring that those policies are carried out by the Authority”. 3.1.2 Article 3(1) of the Act establishes, among other things, that the GCAA is responsible for “ensuring due compliance with the conventions, annexes, protocols and any other relevant standards and recommended practices of the International Civil Aviation Organisation [sic].” It also assigns the GCAA the functions associated with personnel licensing, operations, registration and de-registration of aircraft, along with ensuring the safety of air navigation, the airworthiness of civil aircraft and the environmental protection for aircraft noise and engine emissions. Matters related to ANS are addressed in Sections 21 and 23 of the Act. 3.1.3 Prior to being repealed in November 2004 by the Act, both the Ghana Civil Aviation Authority Law, 1986 (PNDC Law 151) and the Act operated and regulated all State-owned aerodromes in Ghana. In order to separate the regulatory functions from the operation and management of aerodromes, the repeal of PNDC Law 151 restricts the powers of the GCAA, with respect to aerodrome regulation, licensing and safety oversight. Section 44 of the Act provides for transitional provisions stating that “Until the appropriate arrangements are made and effective and efficient mechanisms are set up for a dichotomy establishing an airport management which undertakes the development and management of aerodromes on sound commercial principles, and leaving the authority to focus on airspace management and safety regulations (…) the Authority shall continue to perform the functions under the repealed Act relating to the establishment, development and management of aerodromes”. However, the effective separation of the functions has not yet been implemented, and the GCAA’s responsibility for both regulatory and service provision at airports within Ghana creates a potential conflict of interest. 3.1.4 Article 21 of the Act makes provision for the adoption, promulgation and enforcement of air navigation regulations and addresses all aspects required to regulate civil aviation and air navigation in Ghana. The Director-General of the GCAA, although not being absolved from the ultimate responsibility, is empowered, in terms of Article 9(5) of the Act, to delegate a function to an officer, an employee or an administrative unit under the Director-General, or to an air operator, an aerial work operator, a general aviation operator, a maintenance facility or any other qualified person. While the Director-General is empowered to regulate air navigation, Article 9(7) of the Act limits his or her responsibility to “monitor and enforce compliance with Annexes 1, 6 and 8 to the Chicago Convention and the Organization’s Technical Instructions for safe transport of dangerous goods by air”, and it does not include a reference to all safety-related ICAO Annexes.

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3.1.5 With respect to aircraft accident and incident investigation, Article 25 (1) of the Act empowers the Minister, in accordance with the recommendations of the GCAA by legislative instrument, to make regulations providing for the investigation of an accident arising out of or in the course of air navigation that occurs in or over Ghana or elsewhere to aircraft registered in Ghana. Paragraph 2 of the same article defines the provisions that the regulations may contain, and paragraph 3 provides for the application of punitive actions. However, the Act does not call for the investigation of incidents, including serious incidents, as required by the provisions of ICAO Annex 13. 3.2 Critical element 2 — Specific operating regulations

“The provision of adequate regulations to address, at a minimum, national requirements emanating from the primary aviation legislation and providing for standardized operational procedures, equipment and infrastructures (including safety management and training systems), in conformance with the Standards and Recommended Practices (SARPs) contained in the Annexes to the Convention on International Civil Aviation. Note.— The term ‘regulations’ is used in a generic sense to include instructions, rules, edicts, directives, sets of laws, requirements, policies, orders, etc.”

3.2.1 The Act provides for different regulations to be promulgated in respect of the safety functions of the GCAA, related financial aspects and definition of penalties where it has not been provided for. In this regard, the Act empowers the Director-General to make air navigation regulations by legislative instrument, in consultation with the Minister (Article 21.[1]). However, the Minister may also make regulations relating to the financial aspects of the GCAA, including provisions for penalties for an act committed where a specific penalty has not been provided for (Article 41). Some of the implementing regulations require compliance with both ICAO Annex Standards and Recommended Practices; however, no specific policy reference is made to the application of Recommended Practices, which creates confusion when different values are involved. 3.2.2 Regulations issued by the Director-General allow for the issuance of exemptions to certain safety requirements. However, the Director General has not issued a formal policy stating the circumstances and rationale under which risk assessments may be used in support of an exemption to the requirements, and there is also no formal procedure for issuing and recording exemptions in a systematic manner, including mitigations, time limitations or follow-up actions, as applicable, when the exemption results in a deviation from ICAO Annex Standards. Furthermore, clear procedures for the amendments of the regulations and the notification of differences to ICAO have not been implemented, as there is no dedicated process to determine whether such exemption regimes could lead to non-compliance with applicable ICAO SARPs and, hence, to reportable differences. 3.2.3 The Constitution of the Republic of Ghana requires that any order, rule or regulation made by the Minister or the Director-General be laid before Parliament for a period of twenty-one days before coming into force, unless annulled by a vote of more than two-thirds of Parliament. This process was followed for the issuance of the Civil Aviation Regulations (CARs) of Ghana, dated March 2005, in terms of Legal Instrument (LI )1818, which provides for the establishment of Parts 1 through 14. Parts 15 through 25 of the CARs were established in terms of LI 1824 and came into force on 22 November 2006. 3.2.4 The Director-General of the GCAA is responsible for the efficient administration of the affairs of the GCAA, including the issuance of orders, directives, instructions or circulars to address specific technical matters, and the general operations of the GCAA. Regulations promulgated by the Director-General include personnel licensing; operational requirements; the registration and airworthiness of aircraft in Ghana; provision of ANS; operation of aerodromes; ensuring unimpeded access to aircraft facilities for the purposes

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of inspection; and the detention of aircraft. To supplement regulations, associated Implementing Standards are issued where applicable to allow the GCAA the flexibility to incorporate new practices or procedures as they become available without following the procedures required for promulgation of legally binding regulations. 3.2.5 In the area of personnel licensing, the CARs, Part 1 (General Policies, Procedures and Definitions) addresses matters related to the operation and administrative functions of the GCAA and also includes ICAO Annex 1 provisions. However, regulations promulgated in 2005 under LI 1818 and amended in 2006 through LI 1824 do not provide for the implementation of all Annex 1 provisions. In terms of the process followed, Part 1 was not repealed by LI 1824, and as such, there is now both a Chapter 1 (LI 1824) and a Part 1 (LI 1818) in existence. Parts 2 and 3 of the CARs address personal licensing and aviation training organizations, respectively. 3.2.6 The regulations pertaining to aircraft operations are defined in the CARs, Part 7 (Instruments and Equipment), Part 8 (Operations); Part 9 (Air Operator Certification and Administration); Part 10 (Foreign Air Operators); Part 11 (Aerial Work); and Part 18 (Safe transport of Dangerous Goods by Air). The CARs, Part 9 enables an airline to operate for a six-month validity period with an operating permit which is not in compliance with ICAO Annex 6 requirements. However, the above-mentioned parts do not provide for the implementation of all ICAO Annex 6 and Annex 18 provisions. 3.2.7 In the area of airworthiness, the CARs, Part 4 (Aircraft Registration and Marking), Part 5 (Airworthiness), Part 7 (Instruments and Equipment) and Part 8 (Operations) contain requirements related to the airworthiness of aircraft, issuance of certificates of airworthiness and evaluation and rating of approved maintenance organizations (AMOs). The afore-mentioned together with the Technical Directives issued by the Director-General, which became effective on the date of publication in the Ghana Gazette on 16 November 2006, addresses in general the airworthiness-related provisions of ICAO Annexes 6, 7, 8 and 16. However, the GCAA has not issued or adopted a national code of airworthiness, and accepts type certificates issued by the State of Design for the issuance of a certificate of airworthiness. Clear requirements for the approval of modifications and repairs and aircraft leases between air operators, as well as for the applicability of airworthiness directives from the State of Design, have not been established. 3.2.8 The regulatory framework for the implementation and operation of ANS in Ghana are defined in the CARs, Part 12 (Search and Rescue Services); Part 15 (Aeronautical Information Services); Part 19 (Rules of the Air); Part 20 (Meteorological Service for International Air Navigation); Part 21 (Aeronautical Charts); Part 22 (Units of Measurements to be used in Air and Ground Operations); Part 23 (Aeronautical Telecommunication — Radio Navigation Aids); and Part 24 (Air Traffic Services). However, these CARs have not been harmonized with the Africa-Indian Ocean (AFI) Regional Supplementary Procedures (SUPPs) contained in ICAO Doc 7030, nor have they been reflected in the GCAA operational manuals and the Aeronautical Information Publication (AIP) of Ghana. 3.2.9 With respect to aerodromes, the GCAA has developed and promulgated regulations specific to air navigation through the publication of the CARs, Part 14 (Aerodromes), Volumes I and II, to give effect to the provisions of ICAO Annex 14 and provide additional requirements and guidance. The certification and operation of national and international land aerodromes is regulated under Volume I, and heliport design and operations is regulated under Volume II. However, Volume II has not yet been approved by Parliament. 3.2.10 The CARs, Part 13 (Aircraft Accident and Incident Investigation) contains regulations in respect of the investigation activities following an accident or incident involving civil aircraft/helicopter when it occurs in the territory of Ghana and follows the requirements and recommendations of ICAO Annex 13. It empowers the Minister to nominate or designate any person qualified to be an investigator-in-charge (IIC) for the purpose of initiating and carrying out the investigation immediately and to compile a report. In addition, it

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describes, among other requirements, the powers of the IIC and stipulates that accident prevention is the sole objective of the investigation. 3.3 Critical element 3 — State civil aviation system and safety oversight functions

“The establishment of a civil aviation authority (CAA) and/or other relevant authorities or government agencies, headed by a Chief Executive Officer, supported by the appropriate and adequate technical and non-technical staff and provided with adequate financial resources. The State authority must have stated safety regulatory functions, objectives and safety policies. Note.— The term ‘State civil aviation system’ is used in a generic sense to include all aviation-related authorities with aviation safety oversight responsibility which may be established by the State as separate entities, such as: CAA, airport authorities, air traffic service authorities, accident investigation authority, meteorological authority, etc.”

3.3.1 In November 2004, PNDC Law 151 was repealed and replaced by the Act. The Act provides a transitional period under which GCAA is expected to separate the regulatory and air traffic functions from the airport operations. However, this separation has not yet been implemented, and Section 44 of the Act requires the Authority to continue to perform the functions relating to the establishment, development and management of aerodromes. This creates, for State-owned airports managed by the GCAA, the potential for conflict of interest, especially in the resolution of safety concerns. 3.3.2 The Act establishes the functions of the GCAA as follows: a) the provision, operation and maintenance of airfields and related facilities for aviation in Ghana; b) the provision of navigational/air traffic services (ATS); c) the licensing of aircraft and their personnel operating within GCAA’s jurisdiction; d) the regulation of the air transport industry in Ghana; e) the securing of a sound development of the civil air transport industry in Ghana; f) the co-ordination of activities of the various airlines serving Ghana; and g) advising Government on matters concerning civil aviation generally. Governance of the GCAA is through a Board consisting of the Chairman, the Director-General of Civil Aviation and up to seven other members as appointed by the President of Ghana. The Act establishes that policy direction may be given to the GCAA by the Board; however, it does not include matters relating to the performance of the functions or the exercise of powers by the Board in relation to individual cases. The Director-General of the GCAA and two Deputy Directors-General are also appointed by the President in accordance with article 195 of the Constitution of the Republic of Ghana. The Director-General of the GCAA, as chief executive, is responsible for the efficient administration of the affairs of the GCAA, subject to the directions of the Board on matters of policy, and shall perform any other functions as directed. The GCAA is self funded with its source of revenue from fees for services and other charges and is exempt from the payment of rates and taxes. Adequate income is generated to cover expenditure between regulatory activities (approximately 20 per cent) and service provision (approximately 80 per cent). 3.3.3 The GCAA is organized into two distinct departmental directorates under control of the Deputy Directors-General. The Deputy Director-General (Technical) is responsible for the Safety Regulation Department, Engineering Department and Air Traffic Services Department. The Deputy Director-General (Finance and Administration) is responsible for the Human Resources Department, Finance Department,

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Airport Management Department and Corporate Planning Department. However, overlapping of utilization of staff for some functions is prevalent. 3.3.4 The Director of Safety Regulation is responsible for organizing and maintaining an efficient safety regulatory system for the effective safety oversight of all air transport operators and other stakeholders in Ghana. The Personnel Licensing Section and the Flight Operations Section report to the Deputy Director of Flight Operations, whose supervisor is the Director of Safety Regulation. However, these organizations have not been established by an approved document with clear functions and responsibilities, for example, aircraft maintenance licences are issued by the Airworthiness Section, and the coordinator for dangerous goods is an airworthiness inspector within the Airworthiness Section. 3.3.5 The Deputy Director of Airworthiness, who is also under the supervision of the Director of Safety Regulations, is responsible for ensuring compliance with all requirements relating to the continued airworthiness of aircraft registered in Ghana, foreign-registered aircraft and all air operators operating in Ghana. The Manager of the Airworthiness Section reports to the Deputy Director of Airworthiness and is responsible for ensuring the maintenance of a satisfactory safety oversight capability and supervising the activities of the Airworthiness Section. The responsibilities of the Airworthiness Section include: issuance of certificates of registration and maintenance of the aircraft registry; type certificate acceptance; issuance of noise certificates; issuance and renewal of certificates of airworthiness; special flight permits; approval of air operator maintenance control manuals and maintenance programmes; airworthiness aspects of air operator specific operating provisions; approval of maintenance organizations; surveillance of maintenance organizations and continuing airworthiness responsibilities of State of Registry; reviewing applications for the issuance and renewal of aircraft maintenance engineer (AME) licence; conducting the various inspections required to provide continuing surveillance of all approvals issued; and participating in aircraft incident and accident investigations. However, these responsibilities have not been documented as such. The Airworthiness Section has sufficient technical staff to accomplish the tasks for which it is responsible. Post descriptions have been developed for airworthiness technical staff, including the Deputy Director, manager and aviation safety inspectors. For the purpose of performing their duties, the Director-General has issued inspector credentials to the aviation safety inspectors (airworthiness) delegating the authority to access aviation facilities, detaining aircraft for just cause and prohibiting any person from exercising the privileges of any aviation licence or certificate for just cause. 3.3.6 Three GCAA departments are responsible for addressing aspects related to the establishment and implementation of ANS in Ghana. The Air Traffic Services Department is responsible for the provision of ATS, aeronautical information services (AIS) and search and rescue (SAR) services; the Engineering Department is responsible for communications, navigation and surveillance (CNS) systems; whereas the Safety Regulation Department is responsible for regulatory and safety oversight functions of the services provided. 3.3.7 The Ghana Meteorological Agency was established under Ghana Meteorological Agency Act 682 of 2004 and provides meteorological services (MET) to air navigation through an MOU with the GCAA. The Ghana Meteorological Agency operates a network of more than 400 meteorological stations, including synoptic and aeronautical stations. However, there is no clear separation of authority and responsibility between the State operating agency (Ghana Meteorological Agency) and the regulatory authority (the GCAA) with respect to the implementation of ICAO Annex 3 provisions and to ensure that the public interest is best served. Aeronautical charts (MAP) and visual and instrument flight procedures (Procedures for Air Navigation Services — Aircraft Operations [PANS-OPS]) are provided by a private company (Jeppesen), and flight calibration and testing of radio navigation aids is provided by the Agency for Air Navigation Safety in Africa and Madagascar (ASECNA) through an MOU. The GCAA coordinates issues related to the management and control of the aeronautical frequency spectrum with the National

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Communications Authority, which was established under the National Communications Authority Act, 1996 (Act 524). The National Communications Regulations, 2003, Articles 6, 13, 42, 43 and 46 explicitly recognize the aeronautical fixed services, aeronautical mobile services and the radio navigation services. 3.3.8 In accordance with regional air navigation agreements, Ghana is responsible for the provision of ANS (ATS, CNS, AIS, MET and SAR) within the Accra Flight Information Region (FIR), which includes the high seas, airspace of Benin, Ghana, Sao Tome (partly) and Togo. However, no formal coordination procedures between Ghana and the other member States of the Accra FIR have been established to ensure that their regulations are harmonized. 3.3.9 In the area of aerodromes, during the current transitional phase, all State-owned airports are operated and managed by the GCAA through the Director of the Airport Management Department, who reports to the Deputy Director-General (Finance). These airports include one international airport, the Kotoka International Airport in Accra, three domestic airports (Kumasi, Tamale and Sunyani) and three airstrips. Two privately owned airstrips are also recorded, whilst there is no heliport open to public use. The certification and surveillance activities are the responsibilities of GCAA through its Aerodrome Safety and Standards Section (ASAS). The ASAS is headed by a Deputy-Director which reports to the Director of Safety Regulation. The functions and responsibilities of the ASAS are not clearly defined, and the section includes a unique sub-section headed by the Manager, Aerodrome Safety and Standards, as the Deputy-Director position has not yet been filled. The Manager and the two inspectors staffing the ASAS are from a limited range of professional backgrounds and are stretched to perform a variety of aerodrome certification and inspection tasks, development of regulatory and guidance material and administrative duties, while they all require and are undergoing significant training activities. For its safety oversight activities, the section relies on personnel and inputs from other sections within the Safety Regulations Department, and there is a lack of focus and coordination. The certification process is still in its early stages, and in view of the demanding nature of continuing effective safety oversight activities and the need for enhanced training to cover all the disciplines involved in the certification process, the current staffing level is not adequate to meet the requirements. 3.3.10 Ghana does not have a permanent body dedicated to accidents and serious incidents investigations. The CARs, Part 13, paragraph 13.6 empowers the Minister, when an accident occurs, to order an independent investigation and may nominate or designate any person qualified as an accident investigation inspector to be the IIC for the purpose of initiating and carrying out the investigation immediately and submit a report as soon as possible. The Minister may also appoint a team of investigators to assist the IIC to participate in an investigation. Some trained investigators are available from the GCAA, which will release them from their other assigned duties. Funding for investigations is provided by the Ministry. An additional funding request may be processed when required. 3.4 Critical element 4 — Technical personnel qualification and training

“The establishment of minimum requirements for knowledge and experience of the technical personnel performing safety oversight functions and the provision of appropriate training to maintain and enhance their competence at the desired level. The training should include initial and recurrent (periodic) training.”

3.4.1 Concerning personnel licensing, the systematic and continuous training of all aviation safety inspectors is also the responsibility of the Safety Regulation Department. A training programme has been implemented for the Personnel Licensing Section. The section is staffed by four qualified officers, and there is an on-going process for the recruiting of two additional staff members. 3.4.2 With respect to aircraft operations, the Flight Operations Section is staffed by four flight

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operations inspectors and one cabin safety inspector. The flight operations inspectors are also required to perform ground operations inspections. Most of them have been recruited recently. A training programme has been implemented, and new inspectors are receiving OJT by a senior inspector. 3.4.3 In the area of airworthiness, the Human Resources Management Policy and Administrative Procedures Manual establishes the minimum qualifications required for aviation safety inspectors (airworthiness), including an AME licence, with either an airframe and power plant or an avionics rating, a certificate course on aircraft types on the Ghana register, a certificate course in foreign airworthiness and knowledge in aircraft accident/incident investigation and prevention. In addition, the Aviation Safety Inspectors Handbook contains a requirement for five years or more of working experience in either an airline or the regulatory sector. The training programme established for airworthiness inspectors is also included in the Aviation Safety Inspectors Handbook and addresses initial training needs, including general department orientation, a basic safety inspector’s course and OJT. Each airworthiness inspector is required to complete each task listed on the OJT checklist twice, under the supervision of a senior inspector before being authorized to perform the task on his/her own. The training programme also addresses recurrent training consisting of both advanced and specialized courses designed for experienced aviation safety inspectors, with refresher training to be provided every two years. The Director of Safety Regulations works with the Manager of Airworthiness to develop a yearly training plan based on the results of performance appraisals. The budget for the yearly training plan is reviewed and approved at the Director level and forwarded to the Board for final approval. Once approved, the implementation of the training plan is the responsibility of the Manager of Airworthiness. Training records for airworthiness technical staff, including OJT checklists, are retained in individual staff folders. 3.4.4 The GCAA has established an ANS inspectorate to carry out some safety oversight tasks and regulatory functions over ATS services and supporting CNS infrastructure. The implementation of the related personnel training and qualification processes is in progress. Safety oversight and regulatory functions have not yet been established for AIS, MAP, MET, SAR and PANS-OPS domains. 3.4.5 With respect to aerodromes, the GCAA has established a training policy and programme in the Aerodrome Audit and Certification Manual for its inspectors with civil engineering, electrical engineering and air traffic control backgrounds. The programme includes initial mandatory training and OJT requirements, including appropriate competence and qualification checks to become a qualified and accredited aerodrome safety inspector. The programme also includes training requirements for RFF specialists. However, technical staff has not received training in aerodrome certification and safety oversight concepts, such as safety management systems (SMS), risk assessment/aeronautical study methodologies and evaluation, human factors and bird hazard control. In addition, detailed criteria and training requirements to access different levels of the inspector’s functions have not been defined. The GCAA has a system in place to document individual training records for its technical staff. 3.4.6 As there is no permanent body for accidents and incidents investigations in Ghana, the Minister relies on the availability of appropriately trained staff of the GCAA to carry out the functions of an investigator. The GCAA staff is therefore required to be capable of multi-tasking in their functions and to be trained accordingly. A number of GCAA staff has been subjected to the required training to carry out the responsibilities and duties of an investigator. Foreign organizations provide training for these selected staff members. Training records are maintained in the associated personnel files of staff at the GCAA Human Resources Department; however, planning and training requirements are not adequately documented.

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3.5 Critical element 5 — Technical guidance, tools and the provision of safety critical information

“The provision of technical guidance (including processes and procedures), tools (including facilities and equipment) and safety critical information, as applicable, to the technical personnel to enable them to perform their safety oversight functions in accordance with established requirements and in a standardized manner. In addition, this includes the provision of technical guidance by the oversight authority to the aviation industry on the implementation of applicable regulations and instructions.”

3.5.1 The primary aviation legislation of Ghana is only available to the industry by purchase from the Government Printer. Civil aviation regulations, directives and guidance material for the GCAA technical staff are provided through hard copies and the GCAA intranet. There is also a central and a technical library where relevant regulations and air operators’ manuals are kept. Although legislative and regulatory requirements are in place, procedures and guidance to assist both regulatory staff and the industry in the application of national regulations is limited in scope. 3.5.2 With respect to personnel licensing, the GCAA Aviation Safety Inspectors Handbook, Volume I contains guidance for the aviation safety inspectors to enable them to carry out their tasks, such as procedures for the issuance of licences and medical guidance. Concerning aircraft operations, Volume II of the handbook contains procedures for the certification of air operators and detailed certification processes related to the issuance of an air operator certificate (AOC) and an AMO certificate. A dangerous goods manual has also been developed. 3.5.3 In the area of airworthiness, the Aviation Safety Inspectors Handbook, Volume I, Chapter 4 specifically addresses airworthiness activities, including: maintenance of the civil aircraft register; continuing airworthiness activities; licensing of maintenance personnel; and the issuance of air operators’ certificates. The handbook also contains inspection checklists (Appendix A); application forms (Appendix B); models of certificates, authorizations and licences (Appendix C); and general forms (Appendix D). However, procedures for the acceptance of type certificates have not been developed by the GCAA. In addition, the procedures for the approval of aircraft leases and modifications and repairs are not comprehensive. Furthermore, the checklists used in support of the certification of aircraft operators and AMOs do not address all the requirements. The GCAA has also issued more than thirty airworthiness notices and advisory circulars to provide guidance to the industry. However, these notices and circulars have not been reviewed to ensure consistency with the current regulatory system. Although the Safety Regulation Department has established a technical library containing copies of ICAO Annexes 6, 7, 8 and 16, not all ICAO documents pertaining to airworthiness are available, and some of the Annexes are not up to date. In addition, the Safety Regulation Department relies on air operators to provide copies of the design documentation for the aircraft on the Ghana register, and it does not have access to a method to verify the currency of the information. The Airworthiness Section has been provided with the facilities and equipment it requires for the performance of its tasks and responsibilities. 3.5.4 With respect to ANS, the Air Traffic Services Department is tasked with the implementation of ICAO SARPs as contained in the Air Traffic Services Operations Manual. Aeronautical services are provided, and the Accra international NOTAM office and aerodrome AIS units operate in accordance with ICAO Annex 15 SARPs. The AIP of Ghana is published in three parts in accordance with Annex 15, Chapter 4 and Appendix 1, with aeronautical coordinates expressed in the World Geodetic System – 1984 (WGS-84). 3.5.5 Aerodrome certification procedures are detailed in the Aerodrome Audit and Certification

- 11 -


Manual intended for the industry and regulatory technical staff. A number of checklists have also been developed to assist aerodrome inspectors in the conduct of inspections. However, there is a lack of guidance in specific areas, such as SMS, bird hazard control, the assessment of competence of aerodrome operations staff, aeronautical studies and the development, application and evaluation of risk assessments. Furthermore, the specific functions and responsibilities for both the ASAS and the individual technical staff performing various roles and tasks are not clearly defined, including both inspection and certification processing roles, the resolution of deficiencies, and the review and acceptance of an aerodrome manual. Aerodrome inspectors have internet/intranet access via shared desktop and laptop computers, with ICAO Annexes available in electronic format. Amended ICAO documents and other regulatory material are also available in the Safety Regulation Department’s technical library, as well as in the central library. However, office space and equipment currently allocated to the ASAS is not sufficient to allow the effective accomplishment of their functions and duties. 3.5.6 The GCAA has developed and published the Aircraft Accident Investigation Manual, which contains the procedures for the investigations of major aviation accidents and incidents to be carried out by the Accident Investigation Body (AIB). The manual integrate the requirements of ICAO Annex 13 as well as some State’s specific requirements. Appended to the manual are the initial report (notification) form, a witness/passenger questionnaire and a contact list of the AIB with cellular phone numbers. 3.6 Critical element 6 — Licensing, certification, authorization and/or approval obligations

“The implementation of processes and procedures to ensure that personnel and organizations performing an aviation activity meet the established requirements before they are allowed to exercise the privileges of a licence, certificate, authorization and/or approval to conduct the relevant aviation activity.”

3.6.1 With respect to personnel licensing, as aircrew and other aviation-related training is primarily conducted outside of Ghana in foreign training organizations, most of the activities of the Personnel Licensing Section consist of validation and conversion and renewal of licences, since simulators and instructors are approved for flight training. The following licences are issued by the GCAA: pilot licences (private, commercial and airline); flight engineer’s licences; aircraft maintenance engineer’s licences; and air traffic controller licences. The GCAA conducts examinations on the CARs content, to ensure that licence holders are knowledgeable about the national regulations. The GCAA has recently signed a contract with a medical assessor to assess medical examinations. 3.6.2 In the area of aircraft operations, the certification system established by the GCAA for air operators consists of five phases: initial application; formal application, evaluation of documentation; inspection and demonstration; and issuance of the AOC. However, the procedures contained in the inspector handbook are not used to document the evaluation of manuals. Furthermore, not all air operators have submitted their manuals for approval. In addition, an airline was allowed to operate wet leased aircraft on international flights with an operating permit which was not in compliance with the CARs and ICAO Annex 6 requirements. While a dangerous goods approval has been given to a handling agency, there is no specific approval given to AOC holders, although they might convey dangerous goods from time to time. A recertification process for air operators is currently under way. 3.6.3 With regard to airworthiness, the GCAA issues certificates of airworthiness and noise certificates in accordance with the CARs and the procedures contained in the Aviation Safety Inspectors Handbook. In practice, modifications and repairs must be carried out either in accordance with the approved structural repair manual and manufacturer’s service bulletins or using an approved supplemental type

- 12 -


certificate for a major modification. The procedures used by the aviation safety inspectors (airworthiness) for the review of air operator maintenance control manuals, maintenance programmes and AMO procedures manuals do not ensure that the documents contain all the required contents and that any deficiencies identified during the approval process are documented, retained and resolved prior to approval. In addition, one reduced vertical separation minimum (RVSM) operational approval was issued for an aircraft prior to the request and receipt of a height-keeping monitoring report for the aircraft. There is one domestic AMO in Ghana that has recently completed the certification process. The GCAA validates foreign AMOs based on and contingent upon the validity of the locally approved AMO certificate after the conduct of a physical inspection. However, the CARs do not provide for such an approval, and the validation process does not include an assessment of the local requirements to ensure compliance with the CARs. 3.6.4 With respect to ANS, the GCAA has implemented personnel licensing and qualification processes for air traffic controllers. The licensing of air traffic safety engineers, as part of safety-sensitive personnel as defined in ICAO Annex 2, is also under consideration. The GCAA has also established requirements for the certification and licensing of aeronautical telecommunication stations. In addition, testing, calibration and maintenance of radio navigation aids (instrument landing system, VHF omnidirectional radio-range and distance measuring equipment) are carried out by the GCAA in conformity with ICAO Annex 10 and Doc 8071. However, the CARs, Parts 12, 20 and 24 for the establishment of ATS SMS and quality management systems, in compliance with ICAO Annex 11 and Annexes 3 and 15 respectively, have not yet been implemented. 3.6.5 In the area of aerodromes, Ghana has promulgated legislation and regulations to facilitate the certification of its designated airports used in regular public transport by an aircraft seating capacity of more than thirty passengers. The regulations require the submission of an aerodrome manual and the implementation of an SMS; however, these requirements have not been fully implemented. The GCAA has not developed sufficient guidance material including procedures for its aerodrome personnel and the industry, in particular in some core specialized areas, such as the evaluation of aerodrome staff competence and experience, the development, evaluation and application of risk assessments and aeronautical studies, and SMS. Aerodrome certificates in Ghana remain in force until they are cancelled. However, the certification status of aerodromes is not currently published in the AIP of Ghana. Although the certification process of Kotoka International Airport in Accra has been completed without exemptions, in a number of areas, the GCAA has not ensured the implementation of minimum requirements, such as runway surface condition and friction measurement and reporting, and runway end safety areas, as part of the certification process. In addition, the aerodrome manual approved for Kokota International Airport does not include detailed operating procedures and particulars of the facilities, equipment, personnel and procedures for meeting the requirements for aerodrome services to be provided, such as RFF, bird hazard reduction and removal of disabled aircraft, among others. 3.7 Critical element 7 — Surveillance obligations

“The implementation of processes, such as inspections and audits, to proactively ensure that aviation licence, certificate, authorization and/or approval holders continue to meet the established requirements and function at the level of competency and safety required by the State to undertake an aviation-related activity for which they have been licensed, certified, authorized and/or approved to perform. This includes the surveillance of designated personnel who perform safety oversight functions on behalf of the CAA.”

3.7.1 The GCAA has implemented a surveillance programme for each AOC holder which includes base, apron, station facility and en-route inspections. Some inspections are jointly conducted by the Airworthiness and Personnel Licensing Sections, in coordination with the Flight Operations Section. Ramp

- 13 -


inspections are carried out on foreign air operators. With regard to aircrew training for each AOC holder, a surveillance programme for simulators used by foreign training organizations to provide training has been implemented. 3.7.2 In the area of airworthiness, the Aviation Safety Inspectors Handbook, Volume 1 establishes the frequency of inspections for the various airworthiness surveillance activities and describes the objectives and scope of the different types of inspections, including: ramp inspections, certificate of airworthiness renewal inspections, base inspections and spot inspections. The handbook also provides guidance to inspectors on the documentation of the deficiencies identified during the inspections as well as the communication of those deficiencies to the approval holder. Although the GCAA has established an airworthiness surveillance programme on a biannual basis, there is no visibility on the level of completion of the inspections planned to manage the implementation of the programme. 3.7.3 Concerning ANS, the Safety Regulation Department is responsible for the surveillance and auditing of the ATS provisioning to ensure compliance with the required ICAO provisions in accordance with the Air Traffic Services Audit Manual. The GCAA has implemented one area navigation route with a required navigation performance (RNP) 10 capability. This followed on satisfactory pre-implementation safety assessments, in coordination with all the States involved in its implementation. Similarly, it has developed a National Safety Plan within the framework of the AFI RVSM programme and has submitted it to the AFI Regional Monitoring Agency (ARMA), which is tasked with the performance of related pre-implementation and post-implementation safety assessments. However, no formal arrangements between the GCAA and ARMA have been established with respect to the provision of periodic safety assessments for these RNP and RVSM operations. 3.7.4 In the area of aerodromes, the Act and associated aviation regulations enable the ASAS to conduct surveillance operations for all categories of aerodromes. To this effect, the GCAA has developed and is implementing an inspection programme for its aerodromes. The inspection procedures are included in the Aerodrome Audit and Certification Manual, where provisions are made for initial, periodic and ad hoc inspections. The periodic inspections are carried out according to an annual programme. However, there is a lack of staff in the core team with wider aerodrome operational expertise. Aerodrome inspectors are provided with appropriate credentials that include a legal reference to enable them to take appropriate action in the event of a safety critical finding during audits and inspections. 3.8 Critical element 8 — Resolution of safety concerns

“The implementation of processes and procedures to resolve identified deficiencies impacting aviation safety, which may have been residing in the aviation system and have been detected by the regulatory authority or other appropriate bodies. Note.— This would include the ability to analyse safety deficiencies, forward recommendations, support the resolution of identified deficiencies as well as take enforcement action, when appropriate.”

3.8.1 In the area of personnel licensing, in the case of violation of the applicable laws and regulations by a licence holder, the GCAA conducts an investigation and issues a warning notice. If warranted, enforcement and administrative measures including fines may be taken. 3.8.2 With respect to aircraft operations, the GCAA provides AOC holders with the details of the deficiencies identified during inspections and requires that they submit an action plan for the correction of such identified deficiencies. The GCAA has implemented a follow-up system of the actions taken by AOC

- 14 -


holders. 3.8.3 Volume II of the Aviation Safety Inspectors Handbook provides guidance to airworthiness inspectors for determining the deadlines to be established for the approval holder to provide a corrective action plan for deficiencies identified during inspections. Although the GCAA has established requirements and forms for the reporting of faults, malfunctions and defects, and has issued an airworthiness notice on the subject, the industry visit revealed that this requirement has not been implemented for a recently approved AMO. Furthermore, reports received by the GCAA have not been forwarded to the organization responsible for the type design. In practice, the GCAA expects the industry to comply directly with airworthiness directives issued by the State of Design and does not issue any additional mandatory action. 3.8.4 The GCAA addresses the ANS deficiencies identified within the framework of the AFI Planning and Implementation Regional Group (APIRG). However, there is no adequate coordination with concerned adjacent States/FIRs to ensure that pending issues of safety concern are resolved when encountered. 3.8.5 Formal procedures are not clearly documented in respect of dealing with deficiencies identified during aerodrome inspections or by other means, and until their resolution, aerodrome safety-related deficiencies are notified to the aerodrome operator by letters of correction. These notifications are allocated a priority with time-scales for corrective action, as appropriate. In the event that deficiencies are not rectified, operators may have their aerodrome certificate revoked or suspended. Financial penalties are provided for in the regulations; however, sanctions do not include the imposition of any operating restrictions. In addition, no indication or guidance for the use of this type of sanction has been provided for in any documentation. The development and application of the airport certification programme is still in its early stages, and the resolution of safety concerns has to date not been adequately addressed, an example being the non-compliance with the national requirement for RESA. 3.8.6 In the area of accident and incident investigation, the CARs, Part 13 requires the IIC to compile a report together with recommendations to the Director-General of the GCAA. The Director-General is in turn required to forward this report with comments to the Minister, who may or may not release the report for publication. The process to be followed in the development of the draft report and the circulation thereof to participants is prescribed both in the CARs, Part 13 and the Aircraft Accident Investigation Manual. The CARs, Part 13 also requires the establishment of incident reporting and database systems; however, these systems have not yet been implemented in order to enable readily sharing of accident and incident information. 4. VISITS TO THE INDUSTRY/SERVICE PROVIDERS 4.1 Accompanied by staff members of the State’s civil aviation system, the audit teams visit aviation service providers, operations and maintenance departments of operators and maintenance organizations, aeronautical product/equipment manufacturers, aviation training institutes, etc. The objective of the visits is to validate the capability of the State to supervise the activities of these service providers, airlines and organizations. 4.2 In the case of Ghana, the audit team visited the following organizations: Antrak Air (passengers and freight); MK Airlines: (cargo); and Aviance (handling agency) (PEL/OPS); United Aviation Services, Accra (AIR);

- 15 -


GCAA air navigation facilities and services, including SAR Rescue and Coordination Centre in Accra (ANS); Ghana Meteorological Agency; and Kotoka International Airport (AGA) 5. AUDIT FINDINGS AND DIFFERENCES DATABASE (AFDD) 5.1 The general objective of the AFDD is to assist States in identifying the elements that need attention in the implementation of the proposed corrective action plan. The information is also intended to assist States in establishing a priority of actions to be taken to resolve safety concerns identified by the audits. Appendix 2 to this report contains a graphic representation of the lack of effective implementation of the critical elements of the safety oversight system (ICAO Doc 9734, Part A refers) in Ghana and at a global level (average results from all States audited). The graphic representation enables the audited State to prioritize the necessary corrective actions and to identify assistance requirements based on its personnel, technical and financial capabilities in consideration of its safety oversight obligations. 6. STATE AVIATION ACTIVITY QUESTIONNAIRE (SAAQ) 6.1 The SAAQ is one of the major tools required for conducting a comprehensive systems approach-based safety oversight audit. As such, all Contracting States are required to complete the SAAQ and submit it to ICAO for proper evaluation and recording. The submitted information enables ICAO to maintain an up-to-date database on the State’s civil aviation activities. Ghana has submitted its SAAQ to ICAO, which can be found at www.icao.int/soa. 7. COMPLIANCE CHECKLISTS (CCs) 7.1 The CCs are one of the main tools used in the conduct of safety oversight audits under the comprehensive systems approach. As such, all Contracting States are required to complete the CCs and submit them to ICAO for evaluation and recording. The submitted information enables ICAO to maintain an up-to-date database on the State’s level of compliance to the ICAO SARPs and assist in facilitating the conduct of a standardized audit of all Contracting States. As a result, States will be enabled to have a clear picture of the implementation status of the relevant SARPs. Ghana has submitted its CCs to ICAO, which can be found at www.icao.int/soa. 8. FOLLOW-UP ACTION 8.1 In accordance with the MOU agreed to between Ghana and ICAO, Ghana submitted a corrective action plan on 26 April 2007 and an update to the action plan on 26 July 2007. The action plan submitted was reviewed by the Safety Oversight Audit (SOA) Section and was found to address most of the findings and recommendations contained in this report. The proposed action plan, including comments and clarifications provided by the State, is attached as Appendix 3 to this report. Comments by ICAO on each corrective action are found in Appendix 1 to this report.

— — — — — — — —

APPENDIX 1

Auditee:

Audit Period: 20/11/2006 - 28/11/2006

APPENDIX 1-1-01

LEG/01GHANA

FINDINGS AND RECOMMENDATIONS RELATED TO

PRIMARY AVIATION LEGISLATION AND CIVIL AVIATION REGULATIONS

1.009; 3.001; 4.001; 7.011;

DOCUMENT REFERENCE:

Refer to Doc 9735, Appendix F for the document reference(s) associated with the protocol questions identified in this

finding.

CE-1 CE-2 X CE-3 CE-4 CE-5 CE-6 CE-7 CE-8

FINDING:

The Legal Services Department Procedures Manual of the Ghana Civil Aviation Authority (GCAA) contains procedures

to be followed for the review of the Ghana Civil Aviation Regulations (CARs), subsequent to an amendment of an ICAO

Annex. The Constitution of the Republic of Ghana requires the amendments to the CARs to be laid before Parliament for a

period of twenty-one days prior to coming into force. This is undertaken under cover of a submission known as a Legal

Instrument (LI), and formal notification is given by the Office of Parliament once the House has passed the LI. However,

with the processing of LI 1824, a reference to Chapters 1 and 2 as part thereto was not included in the schedule, thereby

putting the validity of these chapters in doubt. Chapter 2 includes a clause repealing and replacing the entire Part 2 of the

CARs. No such clause is included in Chapter 1, with the effect that there is now both a Chapter 1 and a Part 1 of the CARs

in force dealing with the same requirements. In addition, these CARs do not provide for the implementation of all Annex 1

provisions.

RECOMMENDATION:

The Director-General of the GCAA, in consultation with the Office of the Minister for Civil Aviation and the Office of

Parliament, should review the process in place to ensure the legality and correctness of the CARs and amendments thereto,

as submitted to Parliament for consideration.

CORRECTIVE ACTION PLAN PROPOSED BY THE STATE:

Corrective action plan and comments submitted by the State are found at Appendix 3-1-1 of this report.

COMMENTS BY ICAO:

The corrective action plan submitted by the State partially addresses this ICAO finding and recommendation. The State has

not addressed the implementation of all Annex 1 provisions in the CARs.

Auditee:

Audit Period: 20/11/2006 - 28/11/2006

APPENDIX 1-1-02

LEG/02GHANA



1.025; 3.005; 3.007; 4.003; 4.005; 4.007; 4.333; 5.005;

5.007; 6.017; 7.013; 8.003; 8.015;

DOCUMENT REFERENCE:


finding.


FINDING:

The Legal Services Department Procedures Manual contains procedures to be followed for the verification of compliance

of the CARs with ICAO Annex provisions, subsequent to an ICAO Annex amendment, and includes related technical

coordination and identification and notification of differences to ICAO. The prescribed process involves reference to the

user department and a review by a technical review committee. However, this process has not been implemented and

adhered to, and the minutes or recommendations of the technical review committee are not available.

RECOMMENDATION:

The Director-General of the GCAA should ensure that the procedures developed for the verification and review of the

CARs to ensure compliance with ICAO Annex provisions and the identification and notification of differences are

implemented and adhered to.



Estimated Implementation Date: 26/04/2007

COMMENTS BY ICAO:

The corrective action plan submitted by the State fully addresses this ICAO finding and recommendation

Auditee:

Audit Period: 20/11/2006 - 28/11/2006

APPENDIX 1-1-03

LEG/03GHANA



1.051; 7.041;

DOCUMENT REFERENCE:


finding.

CE-1 X CE-2 X CE-3 CE-4 CE-5 CE-6 CE-7 CE-8

FINDING:

The Ghana Civil Aviation Act, 2004 (Act 678), Article 3(1) establishes that one of the functions of the GCAA is the

responsibility to ensure compliance with the Conventions, Annexes, Protocols and any other relevant ICAO SARPs.

However, Article 9.V(7) of the Act only requires the Director-General of the GCAA to monitor and enforce compliance

with ICAO Annexes 1, 6 and 8 and the Technical Instructions for the safe transport of dangerous goods by air. This

limitation restricts the scope of action and enforcement powers of the Director-General.

RECOMMENDATION:

Ghana should revise the Ghana Civil Aviat ion Act , 2004 (Act 678) in order to extend the responsibi l i ty of the

Director-General to include the monitoring and enforcement of compliance to all safety-related ICAO Annexes.




COMMENTS BY ICAO:

The corrective action plan submitted by the State fully addresses this ICAO finding and recommendation.

Auditee:

Audit Period: 20/11/2006 - 28/11/2006

APPENDIX 1-2-01

ORG/01GHANA


CIVIL AVIATION ORGANIZATION

2.011; 2.021; 7.051; 8.011;

DOCUMENT REFERENCE:


finding.

CE-1 CE-2 CE-3 X CE-4 CE-5 CE-6 CE-7 CE-8

FINDING:

Repeal of Law 151 by the Ghana Civil Aviation Act, 2004 (Act 678) was implemented to provide for the transition of the

separation of functions of the GCAA as both regulator and service provider to solely that of regulator. However, to date,

this transition has not been achieved and does not provide for a clear distinction of responsibilities, creating a potential

conflict of interests.

RECOMMENDATION:

Ghana should proceed with the implementation of the separation of regulatory and service provider functions of the GCAA

to ensure the effective implementation of a safety oversight system in the provisioning of air navigation services and the

certification and operation of aerodromes within Ghana.




COMMENTS BY ICAO:


Auditee:

Audit Period: 20/11/2006 - 28/11/2006

APPENDIX 1-2-02

ORG/02GHANA



3.101; 4.021; 4.027; 5.023;

DOCUMENT REFERENCE:


finding.


FINDING:

The GCAA Human Resources Management Policy and Administrative Procedures Manual contains the functions and

responsibilities of the Safety Regulations Department as well as job descriptions for management staff and aviation safety

inspectors. However, the functions and responsibilities of the lower level departments and sections have not been clearly

defined.

RECOMMENDATION:

The GCAA should clearly define all the functions and responsibilities of each of its departments and sections and include

them in the Human Resources Management Policy and Administrative Procedures Manual.




COMMENTS BY ICAO:


Auditee:

Audit Period: 20/11/2006 - 28/11/2006

APPENDIX 1-2-03

ORG/03GHANA



2.019; 7.415;

DOCUMENT REFERENCE:


finding.


FINDING:

The Ghana Meteorological Agency (GMA) under the Ministry of Communications and Technology is the sole authority

responsible for meteorological services (MET) - related matters in Ghana, including the provision of MET for international

air navigation in conformance with ICAO Annex 3. Accordingly, a Memorandum of Understanding (MOU) was signed

between the GCAA and the GMA. However, the MOU does not establish a clear separation between the regulatory

functions, including safety oversight functions, and the service provision functions.

RECOMMENDATION:

The GCAA should ensure that a clear separation is established between the regulatory functions and service provision

functions with respect to the implementation of ICAO Annex 3 provisions pertaining to MET for international air

navigation.




COMMENTS BY ICAO:


Auditee:

Audit Period: 20/11/2006 - 28/11/2006

APPENDIX 1-2-04

ORG/04GHANA



2.201; 5.101; 5.103; 7.039;

DOCUMENT REFERENCE:


finding.

CE-1 CE-2 CE-3 CE-4 CE-5 X CE-6 CE-7 CE-8

FINDING:

The GCAA has established both a central and technical library for the use of GCAA personnel to access ICAO Annexes

and associated guidance material and other documentation. However, various versions of publications (both in hard and

soft copy format) in use by GCAA staff do not clearly indicate the validity or currency status of the documents.

Furthermore, the technical library does not contain up-to-date copies of all ICAO Annexes and related guidance material.

The documents stored in the archives are not marked as such, and there is no system in place to ensure the currency of

design organization documentation.

RECOMMENDATION:

The GCAA should establish and implement a process that ensures that relevant information is readily available to staff and

users. Both the central and technical libraries should introduce a system that clearly identifies the latest current version of

documents available to staff. Uncontrolled versions of documents should be clearly marked as such.




COMMENTS BY ICAO:


Auditee:

Audit Period: 20/11/2006 - 28/11/2006

APPENDIX 1-2-05

ORG/05GHANA



2.205;

DOCUMENT REFERENCE:


finding.


FINDING:

The GCAA has not provided adequate facilities for the Flight Operations and Aerodrome Sections to allow them to

effectively accomplish their functions and duties.

RECOMMENDATION:

The GCAA should ensure that its technical staff is provided with adequate facilities to allow it to effectively accomplish its

functions and duties.




COMMENTS BY ICAO:


Auditee:

Audit Period: 20/11/2006 - 28/11/2006

APPENDIX 1-3-01

PEL/01GHANA


PERSONNEL LICENSING AND TRAINING

3.405;

DOCUMENT REFERENCE:


finding.

CE-1 CE-2 CE-3 CE-4 CE-5 CE-6 X CE-7 CE-8

FINDING:

The GCAA uses the services of a medical assessor; however, the reports submitted by designated medical examiners are

not evaluated. In addition, there is an overlap of the functions of the medical assessor and those of the GCAA Medical

Board.

RECOMMENDATION:

The GCAA should carry out the evaluation of all medical reports submitted by the designated medical examiners and

clearly define the functions of the medical assessor and those of the GCAA Medical Board.




COMMENTS BY ICAO:


Auditee:

Audit Period: 20/11/2006 - 28/11/2006

APPENDIX 1-3-02

PEL/02GHANA



3.459;

DOCUMENT REFERENCE:


finding.

CE-1 CE-2 CE-3 CE-4 CE-5 CE-6 CE-7 X CE-8

FINDING:

The GCAA has not implemented a system for the supervision and control of medical examiners.

RECOMMENDATION:

The GCAA should implement a system for the supervision and control of medical examiners.




COMMENTS BY ICAO:


Auditee:

Audit Period: 20/11/2006 - 28/11/2006

APPENDIX 1-3-03

PEL/03GHANA



3.503; 3.505; 3.507;

DOCUMENT REFERENCE:


finding.

CE-1 CE-2 CE-3 X CE-4 X CE-5 CE-6 X CE-7 CE-8

FINDING:

The GCAA has not implemented a system to ensure consistency and reliability of testing by the designated/delegated

organizations or examiners, for written and oral examinations and to ensure that the examiners have the required

qualifications for their appointment.

RECOMMENDATION:

The GCAA should implement a system to ensure consistency and reliability of testing by the designated/delegated

organizations or examiners for written and oral examinations and to ensure that the examiners have the required

qualifications for their appointment.




COMMENTS BY ICAO:


Auditee:

Audit Period: 20/11/2006 - 28/11/2006

APPENDIX 1-3-04

PEL/04GHANA



3.751; 3.753; 3.755;

DOCUMENT REFERENCE:


finding.

CE-1 CE-2 CE-3 CE-4 CE-5 CE-6 X CE-7 X CE-8

FINDING:

The GCAA has not established a system for the certification (authorization) of aviation training organizations for the

training of air traffic controllers and aircraft maintenance engineers (AME). In addition, it does not ensure the qualification

and competency of the delegated instructors from the training organizations, nor is any surveillance conducted of the

delegated tasks.

RECOMMENDATION:

The GCAA should establish a system for the certification (authorization) of aviation training organizations involved in the

training of air traffic controllers and AME. It should also ensure proper surveillance of the delegated tasks and monitoring

of the qualification and competency of the instructors of these training organizations.




COMMENTS BY ICAO:


Auditee:

Audit Period: 20/11/2006 - 28/11/2006

APPENDIX 1-3-05

PEL/05GHANA



3.801; 3.805; 3.807; 3.813;

DOCUMENT REFERENCE:

Refer to Doc 9735, Appendix F for the document reference(s) associated with the protocol questions identified in this finding.

CE-1 CE-2 X CE-3 CE-4 CE-5 X CE-6 X CE-7 CE-8 X

FINDING:

In practice, the GCAA converts and validates foreign AME licences issued by other ICAO Contracting States. However,

the requirements established in the CARs only address the issuance and validation of AME licences. In addition, the

GCAA does not ensure that the requirements under which the original AME licences were issued meet the CARs or ICAO

Annex 1 provisions, nor does it verify the validity of the original licences with the issuing authority. One approved

maintenance organization (AMO) file reviewed contained evidence of an AME violating the conditions of his licence and

letters of notification to the AME and the employing AMO. Although a response from the AME was received, and he did

not apply for the renewal of his licence, no further action on the part of the GCAA was taken, and there was nothing in the

AME’s file documenting the occurrence.

RECOMMENDATION:

The GCAA should establish requirements and procedures for the conversion and validation of foreign AME licences to

ensure that the original licences issued conform to ICAO Annex 1 provisions and the CARs, as well as confirm the validity

of the original licences with the issuing authority. In addition, the GCAA should ensure that any evidence of an AME not

performing his/her duties in accordance with the prescribed privileges and conditions of his/her licence is appropriately

followed up and resolved with associated records retained in the AME’s file.




COMMENTS BY ICAO:


Auditee:

Audit Period: 20/11/2006 - 28/11/2006

APPENDIX 1-4-01

OPS/01GHANA


AIRCRAFT OPERATIONS CERTIFICATION AND SUPERVISION

4.011; 4.101; 4.103; 4.105; 4.143; 4.161; 4.181; 4.221;

4.241; 4.251; 4.253; 4.261; 4.263; 4.321; 4.323; 4.325;

5.265; 5.281;

DOCUMENT REFERENCE:


finding.

CE-1 CE-2 X CE-3 CE-4 CE-5 X CE-6 X CE-7 X CE-8

FINDING:

The GCAA has established a certification system for air operators. However, the CARs, Part 9 provides for the granting of

an operating permit, which is not in compliance with Annex 6 requirements. This has allowed an applicant for an air

operator certificate (AOC) to start international flights with wet leased aircraft without complying with the CARs and

Annex 6 requirements. Furthermore, although the CARs only allow an operating permit to be issued for a period not

exceeding six months, one operating permit was issued for a period of one year and subsequently renewed for a second one

year period. In addition, no significant differences between the CARs and ICAO Annex 6 have been published in the AIP

of Ghana in this regard.

RECOMMENDATION:

The GCAA should cert ify al l air operators in accordance to ICAO Annex 6 requirements prior to any operation.

Furthermore, it should publish in the AIP of Ghana significant differences between the CARs and ICAO Annex 6, in

particular the provisions relating to the granting air operators with an operating permit which is not in compliance with

Annex 6 requirements.




COMMENTS BY ICAO:


Auditee:

Audit Period: 20/11/2006 - 28/11/2006

APPENDIX 1-4-02

OPS/02GHANA



4.123; 4.141; 4.165; 4.171; 4.189;

DOCUMENT REFERENCE:


finding.

CE-1 CE-2 CE-3 CE-4 CE-5 X CE-6 X CE-7 CE-8

FINDING:

The GCAA does not ensure that the requirements on the contents and the structure of the air operators' operations manual

are respectively complied with and maintained up to date, as provided for in ICAO Annex 6. In addition, the GCAA does

not ensure that all air operators establish a route guide to be used by their flight crew and develop and submit for approval

a minimum equipment list/deviation configuration list (MEL/CDL).

RECOMMENDATION:

The GCAA should ensure that the requirements on the contents and the structure of the air operators' operations manual

are respectively complied with and maintained up to date, as provided for in ICAO Annex 6. In addition, the GCAA should

ensure that all parts of the operations manual, including route guide and MEL/CDL, are submitted for approval by all air

operators.




COMMENTS BY ICAO:


Auditee:

Audit Period: 20/11/2006 - 28/11/2006

APPENDIX 1-4-03

OPS/03GHANA



4.121;

DOCUMENT REFERENCE:


finding.


FINDING:

The GCAA does not ensure that an applicant for an AOC establishes and maintains a flight safety documents system, as

required by ICAO Annex 6.

RECOMMENDATION:

The GCAA should ensure that an applicant for an AOC establishes and maintains a flight safety documents system, as

required by ICAO Annex 6.




COMMENTS BY ICAO:


Auditee:

Audit Period: 20/11/2006 - 28/11/2006

APPENDIX 1-4-04

OPS/04GHANA



4.203; 4.205;

DOCUMENT REFERENCE:


finding.


FINDING:

The GCAA does not ensure that the accident prevention programmes established by air operators contain a non-punitive

flight data analysis programme, as required by ICAO Annex 6.

RECOMMENDATION:

The GCAA should ensure that the accident prevention programmes established by air operators contain a non-punitive

flight data analysis programme, as required by ICAO Annex 6.




COMMENTS BY ICAO:


Auditee:

Audit Period: 20/11/2006 - 28/11/2006

APPENDIX 1-4-05

OPS/05GHANA



4.335; 4.345; 4.347; 4.349; 4.351; 4.355; 4.361; 4.363;

4.365;

DOCUMENT REFERENCE:


finding.

CE-1 CE-2 CE-3 X CE-4 CE-5 CE-6 X CE-7 CE-8

FINDING:

The GCAA has not notified ICAO of the appropriate authority responsible for the safe transport of dangerous goods by air.

In addition, the GCAA has not ensured compliance with all dangerous goods-related requirements in the certification

process of air operators. The GCAA also does not conduct inspections related to dangerous goods.

RECOMMENDATION:

The GCAA should:

a) notify ICAO of the appropriate authority responsible for the safe transport of dangerous goods by air;

b) ensure compliance with all dangerous goods-related requirements in the certification process of air operators,

including the training of their staff in dangerous goods and the development of an acceptance checklist;

c) issue operations specification mentioning whether or not the air operator is authorized to carry dangerous

goods; and

d) conduct inspections related to dangerous goods.




COMMENTS BY ICAO:


Auditee:

Audit Period: 20/11/2006 - 28/11/2006

APPENDIX 1-4-06

OPS/06GHANA



4.187; 4.231; 4.235;

DOCUMENT REFERENCE:


finding.

CE-1 CE-2 CE-3 CE-4 CE-5 CE-6 X CE-7 X CE-8

FINDING:

The GCAA does not ensure that air operators establish a flight dispatcher training programme prior to the issuance of an

AOC. In addition, the GCAA does not ensure that, on a recurrent basis, the knowledge, skills and qualifications of flight

dispatch ground instructors are maintained, as required by ICAO Annex 6.

RECOMMENDATION:

The GCAA should ensure that air operators establish a flight dispatcher training programme prior to the issuance of an

AOC and that, on a recurrent basis, the knowledge, skills and qualifications of flight dispatch ground instructors are

maintained, as required by ICAO Annex 6.




COMMENTS BY ICAO:


Auditee:

Audit Period: 20/11/2006 - 28/11/2006

APPENDIX 1-4-07

OPS/07GHANA



4.131; 4.133;

DOCUMENT REFERENCE:


finding.

CE-1 CE-2 X CE-3 CE-4 CE-5 CE-6 CE-7 X CE-8

FINDING:

The GCAA does not ensure that air operators maintain up-to-date and sufficient documentation concerning flight data

recorder (FDR) parameter al locat ion and conversion equations, nor does i t ensure their avai labi l i ty to accident

investigation authorities, as required by ICAO Annex 6.

RECOMMENDATION:

The GCAA should ensure that air operators maintain up-to-date and sufficient documentation concerning FDR parameter

allocation and conversion equations and also ensure their availability to accident investigation authorities, as required by

ICAO Annex 6.




COMMENTS BY ICAO:


Auditee:

Audit Period: 20/11/2006 - 28/11/2006

APPENDIX 1-4-08

OPS/08GHANA



4.445;

DOCUMENT REFERENCE:


finding.


FINDING:

The GCAA has established a surveillance programme of air operators; however, this programme does not take into account

the monitoring of the air operators' financial conditions.

RECOMMENDATION:

The GCAA should include the monitoring of the air operator's financial conditions in the surveillance programme.




COMMENTS BY ICAO:


Auditee:

Audit Period: 20/11/2006 - 28/11/2006

APPENDIX 1-4-09

OPS/09GHANA



4.401;

DOCUMENT REFERENCE:


finding.


FINDING:

The GCAA does not ensure that air operators establish a policy and procedures to enable cabin crew to discreetly

communicate with flight crew in the event of suspicious activity or security breach in the passenger cabin.

RECOMMENDATION:

The GCAA should ensure that air operators establish a policy and procedures to enable cabin crew to discreetly

communicate with flight crew in the event of suspicious activity or security breach in the passenger cabin.




COMMENTS BY ICAO:


Auditee:

Audit Period: 20/11/2006 - 28/11/2006

APPENDIX 1-5-01

AIR/01GHANA


AIRWORTHINESS OF AIRCRAFT

5.149;

DOCUMENT REFERENCE:


finding.


FINDING:

The GCAA has not developed procedures for the acceptance of type certificates required for the issuance of a standard or

special certificate of airworthiness in accordance with the technical directives published on the Ghana Gazette on 16

November 2006.

RECOMMENDATION:

The GCAA should develop procedures for the acceptance of type certificates required for the issuance of a standard or

special certificate of airworthiness in accordance with the technical directives published on the Ghana Gazette on 16

November 2006.




COMMENTS BY ICAO:


Auditee:

Audit Period: 20/11/2006 - 28/11/2006

APPENDIX 1-5-02

AIR/02GHANA



5.171; 5.173;

DOCUMENT REFERENCE:


finding.

CE-1 CE-2 X CE-3 CE-4 CE-5 X CE-6 CE-7 CE-8

FINDING:

The GCAA has not established clear requirements and procedures for the approval of modifications and repairs, including

the need for the engineering data to be approved and guidelines on what is acceptable as approved data.

RECOMMENDATION:

The GCAA should establish clear requirements and procedures for the approval of modifications and repairs, including the

need for the engineering data to be approved and guidelines on what is acceptable as approved data.




COMMENTS BY ICAO:


Auditee:

Audit Period: 20/11/2006 - 28/11/2006

APPENDIX 1-5-03

AIR/03GHANA



5.211; 5.213; 5.215;

DOCUMENT REFERENCE:


finding.


FINDING:

The Ghana CARs imply that the GCAA will take some action in order for airworthiness directives (ADs) from the State of

Design to apply to Ghana-registered aircraft, when in fact, the intention is for the ADs to apply directly. The CARs also

provide for additional airworthiness action to be taken; however, procedures have not been developed for determining

when additional action is necessary and coordinating with the State of Design.

RECOMMENDATION:

The GCAA should ensure that the applicability of ADs for Ghana-registered aircraft in the CARs along with any additional

action taken by the GCAA (if any) mandate compliance with the ADs from the State of Design. In addition, should a

provision for taking additional mandatory action be provided for in the CARs, procedures should be developed for

determining when additional action is necessary and coordinating with the State of Design.




COMMENTS BY ICAO:


Auditee:

Audit Period: 20/11/2006 - 28/11/2006

APPENDIX 1-5-04

AIR/04GHANA



5.535;

DOCUMENT REFERENCE:


finding.


FINDING:

The GCAA has not established a requirement for human factors principles to be observed in the design and application of

maintenance programmes in conformance with ICAO Annex 6.

RECOMMENDATION:

The GCAA should establish a requirement for human factors principles to be observed in the design and application of

maintenance programmes in conformance with ICAO Annex 6.




COMMENTS BY ICAO:


Auditee:

Audit Period: 20/11/2006 - 28/11/2006

APPENDIX 1-5-05

AIR/05GHANA



5.243; 5.245;

DOCUMENT REFERENCE:


finding.


FINDING:

The procedures and forms for the issuance of export airworthiness approvals established by the GCAA do not include

determining if the importing State has any special regulatory requirements and specifying the compliance status with these

requirements on the approval issued.

RECOMMENDATION:

The GCAA should amend the procedures and forms for the issuance of airworthiness approvals to include determining if

the importing State has any special regulatory requirements and specifying the compliance status with these requirements

on the approval issued.




COMMENTS BY ICAO:


Auditee:

Audit Period: 20/11/2006 - 28/11/2006

APPENDIX 1-5-06

AIR/06GHANA



5.253; 5.255;

DOCUMENT REFERENCE:


finding.


FINDING:

The airworthiness notices issued to date by the GCAA have not been reviewed to ensure that they reflect the current

regulatory system. Furthermore, when a new airworthiness notice is issued, previous notices on the same subject are not

cancelled or superseded as appropriate. In addition, the GCAA has not developed and published industry guidelines for the

proper usage of parts removed from an aircraft no longer in service, including parts from aircraft involved in accidents, or

for the disposal of scrapped parts.

RECOMMENDATION:

The GCAA should review and update the existing airworthiness notices in order to ensure that they reflect the current

regulatory system of Ghana. Furthermore, the GCAA should develop procedures to ensure that prior to the issuance of any

new airworthiness notice, previous notices on the same subject are cancelled to ensure a coherent system. In addition, the

GCAA should develop and publish industry guidelines for the proper usage of parts removed from an aircraft no longer in

service, including parts from aircraft involved in accidents, or for the disposal of scrapped parts.




COMMENTS BY ICAO:


Auditee:

Audit Period: 20/11/2006 - 28/11/2006

APPENDIX 1-5-07

AIR/07GHANA



5.285; 5.287; 5.305; 5.307; 5.397; 5.429;

DOCUMENT REFERENCE:


finding.


FINDING:

The procedures used by the GCAA aviation safety inspectors (airworthiness) for the review of the air operators '

maintenance control manuals and maintenance programmes and AMO procedures manuals do not ensure that the

documents contain al l the required contents and that any deficiencies identif ied during the approval process are

documented, retained and resolved prior to approval.

RECOMMENDATION:

The GCAA should develop checklists for the review of the air operators' maintenance control manuals and maintenance

programmes and AMO procedures manuals to ensure that the documents contain all required contents and that any

deficiencies identified during the approval process are documented, retained and resolved prior to approval.




COMMENTS BY ICAO:


Auditee:

Audit Period: 20/11/2006 - 28/11/2006

APPENDIX 1-5-08

AIR/08GHANA



5.333;

DOCUMENT REFERENCE:


finding.


FINDING:

The GCAA has established procedures for the approval of reduced vertical separation minimum (RVSM) operations.

However, contrary to the established procedures, one RVSM operational approval was issued to an aircraft prior to

requesting and receiving a height-keeping monitoring report for the aircraft.

RECOMMENDATION:

The GCAA should ensure that the procedures for RVSM operational approval are strictly adhered to.




COMMENTS BY ICAO:


Auditee:

Audit Period: 20/11/2006 - 28/11/2006

APPENDIX 1-5-09

AIR/09GHANA



5.341; 5.343; 5.345;

DOCUMENT REFERENCE:


finding.

CE-1 CE-2 X CE-3 CE-4 CE-5 X CE-6 X CE-7 CE-8

FINDING:

The GCAA has not established requirements and procedures for the approval of the various types of leases among

commercial air transport operators, including the airworthiness aspects that should be addressed.

RECOMMENDATION:

The GCAA should establish clear requirements and procedures for the approval of the various types of leases among

commercial air transport operators, including the airworthiness aspects that should be addressed.




COMMENTS BY ICAO:


Auditee:

Audit Period: 20/11/2006 - 28/11/2006

APPENDIX 1-5-10

AIR/10GHANA



5.375; 5.377;

DOCUMENT REFERENCE:


finding.


FINDING:

In practice, the GCAA validates foreign AMOs based on, and contingent upon, the validity of the locally approved AMO

certificate after the conduct of a physical inspection. However, the CARs do not provide for such an approval, and the

procedures for validation do not specify that a local CAA approval is required, nor do they include an assessment of the

local requirements to ensure compliance with the CARs.

RECOMMENDATION:

The GCAA should establish requirements and develop procedures for the validation of foreign AMOs in accordance with

its current practice, to include the need for the foreign AMO to have and maintain an approval from the local CAA and for

the assessment of the local requirements to ensure compliance with the CARs.




COMMENTS BY ICAO:


Auditee:

Audit Period: 20/11/2006 - 28/11/2006

APPENDIX 1-5-11

AIR/11GHANA



5.443;

DOCUMENT REFERENCE:


finding.


FINDING:

The GCAA has established an airworthiness surveillance programme on a biannual basis that includes ramp inspections,

certificate of airworthiness renewal inspections, base inspections and spot inspections. However, no system has been

implemented to monitor the completion of inspections planned.

RECOMMENDATION:

The GCAA should establish a system to monitor the airworthiness surveillance programme and ensure the continuing

supervision of the operations conducted by AOC holders and AMOs.




COMMENTS BY ICAO:


Auditee:

Audit Period: 20/11/2006 - 28/11/2006

APPENDIX 1-5-12

AIR/12GHANA



5.217;

DOCUMENT REFERENCE:


finding.

CE-1 CE-2 CE-3 CE-4 CE-5 CE-6 CE-7 CE-8 X

FINDING:

The GCAA has established requirements and forms for the reporting of faults, malfunctions and defects, and issued an

airworthiness notice on the subject; however, this requirement has not been implemented for a recently approved AMO,

and reports received by the GCAA have not been forwarded to the organization responsible for the type design.

RECOMMENDATION:

The GCAA should ensure that AMOs and AOC holders are aware of the requirements for the reporting of faults ,

malfunctions and defects, and that the reports are forwarded to the organization responsible for the type design.




COMMENTS BY ICAO:


Auditee:

Audit Period: 20/11/2006 - 28/11/2006

APPENDIX 1-6-01

AIG/01GHANA


AIRCRAFT ACCIDENT AND INCIDENT INVESTIGATION

6.001;

DOCUMENT REFERENCE:


finding.

CE-1 X CE-2 CE-3 CE-4 CE-5 CE-6 CE-7 CE-8

FINDING:

The Ghana Civil Aviation Act, 2004 (Act 678) empowers the Minister to make regulations for the investigation of aircraft

accidents. However, the Act has not been amended to keep abreast of amendments to ICAO Annex 13 to provide for

revised procedures related to the investigation of accidents and incidents, including serious incidents, the reporting thereof

and preventive actions to be instituted.

RECOMMENDATION:

Ghana should amend the Ghana Civil Aviation Act, 2004 (Act 678) to reflect the current procedures relating to the

investigation of accidents and incidents contained in ICAO Annex 13. This amendment should include the empowerment

of the Minister to make regulations for the investigation of accidents and incidents, including serious incidents.




COMMENTS BY ICAO:


Auditee:

Audit Period: 20/11/2006 - 28/11/2006

APPENDIX 1-6-02

AIG/02GHANA



6.007; 6.313; 6.315;

DOCUMENT REFERENCE:


finding.

CE-1 CE-2 X CE-3 X CE-4 CE-5 CE-6 CE-7 CE-8

FINDING:

The address and contact numbers provided by the GCAA in the Aircraft Accident Investigation Manual are not up to date.

Furthermore, the AIP of Ghana, which convey the information to all stake holders worldwide, does not include the address

and contact numbers to report an accident or incident.

RECOMMENDATION:

The GCAA should update its contact information contained in the Aircraft Accident Investigation Manual for the

notification of accidents and serious incidents and ensure that it is published in the AIP of Ghana and forwarded to ICAO

for inclusion in Doc 9756. In addition, the contact information should be made unavailable on the accident/incident data

reporting (ADREP) page of the ICAO-NET website.




COMMENTS BY ICAO:


Auditee:

Audit Period: 20/11/2006 - 28/11/2006

APPENDIX 1-6-03

AIG/03GHANA



6.023; 6.025;

DOCUMENT REFERENCE:


finding.


FINDING:

The CARs, Part 13, paragraph 13.7.1 defines the powers of the investigator-in-charge of aircraft accidents; however, there

is no regulation in place giving investigators the power for unhampered access to air traffic services (ATS) recordings.

RECOMMENDATION:

The GCAA should revise the CARs, Part 13 to ensure that the investigator-in-charge has unhampered access to ATS

recordings and documents to enable a detailed examination during an aircraft accident investigation.




COMMENTS BY ICAO:


Auditee:

Audit Period: 20/11/2006 - 28/11/2006

APPENDIX 1-6-04

AIG/04GHANA



6.121;

DOCUMENT REFERENCE:


finding.


FINDING:

The GCAA Aircraft Accident Investigation Manual , paragraph 4.2 defines the eligibility of participants to receive

accreditation by the Accident Investigation Board during an investigation. However, the entitlements and obligations in the

authorizations issued to accredited representatives and advisers are not clearly defined.

RECOMMENDATION:

The GCAA should revise the Aircraft Accident Investigation Manual to include a procedure for the issuance of credentials

to accredited representatives and advisers, including a clear indication of their participation rights and obligations.




COMMENTS BY ICAO:


Auditee:

Audit Period: 20/11/2006 - 28/11/2006

APPENDIX 1-6-05

AIG/05GHANA



6.125;

DOCUMENT REFERENCE:


finding.

CE-1 CE-2 CE-3 CE-4 X CE-5 CE-6 CE-7 CE-8

FINDING:

The GCAA Aircraft Accident Investigation Manual, Appendix E contains an overview of a generic two-year training

programme for accident investigators; however, there is a lack of a detailed training plan and prioritization of the type of

training to be provided.

RECOMMENDATION:

The GCAA should ensure that a periodic t raining plan for accident and incident invest igators is developed and

implemented, detailing and prioritizing the type of training to be provided during an established period.




COMMENTS BY ICAO:


Auditee:

Audit Period: 20/11/2006 - 28/11/2006

APPENDIX 1-6-06

AIG/06GHANA



6.201; 6.207;

DOCUMENT REFERENCE:


finding.


FINDING:

The GCAA provides accident invest igators with basic equipment to enable the conduct of an accident / incident

investigation. However, the investigators are not provided with protective equipment against biological and other hazards

at accident sites.

RECOMMENDATION:

The GCAA should provide accident investigators with protective equipment against biological hazards and other hazards

at accident sites.




COMMENTS BY ICAO:


Auditee:

Audit Period: 20/11/2006 - 28/11/2006

APPENDIX 1-6-07

AIG/07GHANA



6.405;

DOCUMENT REFERENCE:


finding.


FINDING:

The Ghana CARs, Part 13, Chapter 13.12 requires the investigator-in-charge to submit a report to the Director-General of

the GCAA, who in turn is required to forward the report to the Minister responsible for civil aviation. However, the

investigator-in-charge and the investigator-in-chief report directly to the Minister, which creates a potential conflict of

interest and the perception that the investigation may not be conducted impartially and independently.

RECOMMENDATION:

The Minister responsible for civil aviation should establish a reporting procedure that ensures full independence of the

aircraft accident or incident investigation without the involvement of the GCAA in the reporting procedure.




COMMENTS BY ICAO:


Auditee:

Audit Period: 20/11/2006 - 28/11/2006

APPENDIX 1-6-08

AIG/08GHANA



6.409;

DOCUMENT REFERENCE:


finding.


FINDING:

The GCAA Aircraft Accident Investigation Manual, Chapter 7 describes the procedure for the processing of comments

received from the States that participated in the investigation. However, the procedure does not include the process of

seeking comments from the operator through the State of the Operator or from the organizations responsible for the type

design and the final assembly of the aircraft through the State of Design and the State of Manufacture, respectively.

RECOMMENDATION:

The GCAA should revise the Aircraft Accident Investigation Manual to include a procedure to ensure that a copy of the

draft final report is sent to the operator, through the State of the Operator, and to the organizations responsible for the type

design and the final assembly the the aircraft, through the State of Design and the State of Manufacture, respectively, to

enable the operator and these organizations to submit their comments.




COMMENTS BY ICAO:


Auditee:

Audit Period: 20/11/2006 - 28/11/2006

APPENDIX 1-6-09

AIG/09GHANA



6.435; 6.437;

DOCUMENT REFERENCE:


finding.


FINDING:

The Ghana CARs, Part 13.17 requires Ghana to forward a notification of an accident or serious incident to the interested

parties. However, ICAO has not always been included in the notifications of accidents or serious incidents as required and

when applicable.

RECOMMENDATION:

The GCAA should ensure that notifications of accidents or serious incidents, when applicable, are forwarded to ICAO with

a minimum of delay.




COMMENTS BY ICAO:


Auditee:

Audit Period: 20/11/2006 - 28/11/2006

APPENDIX 1-6-10

AIG/10GHANA



6.503; 6.505; 6.509; 6.511;

DOCUMENT REFERENCE:


finding.

CE-1 CE-2 X CE-3 CE-4 CE-5 CE-6 CE-7 CE-8 X

FINDING:

The Ghana CARs, Part 13.25 defines the establishment of a voluntary incident report ing system, which shal l be

non-punitive and afford protection to the sources of information, and the establishment of a data base, using standardized

formats to facilitate data exchange and effective analysis of the information. However, the GCAA has not yet implemented

the voluntary incident reporting system, including the associated non-punitive procedures, and the data base.

RECOMMENDATION:

The GCAA should establish a voluntary and non-punitive incident reporting system as well as an accident and incident

data base using standardized formats to facilitate the effective analysis of the information obtained.




COMMENTS BY ICAO:


Auditee:

Audit Period: 20/11/2006 - 28/11/2006

APPENDIX 1-7-01

ANS/01GHANA


AIR NAVIGATION SERVICES

7.001;

DOCUMENT REFERENCE:


finding.

CE-1 X CE-2 CE-3 CE-4 CE-5 CE-6 CE-7 CE-8

FINDING:

The CARs, Part 19 (Rules of the Air) and Part 24 (Air Traffic Services) are in conformance with ICAO Annexes 2 and 11

provisions. However, these regulations do not reflect Africa Indian Ocean (AFI) Regional Supplementary Procedures

(SUPPs) contained in ICAO Doc 7030, and the Ghana AIP, GEN 1.7 contains some differences from Annex 2.

RECOMMENDATION:

The GCAA should ensure that the requirements of ICAO Annexes 2 and 11 over the high seas airspace, for which Ghana

has accepted responsibility for the provision of ATS, are applicable without exception and that the CARs are harmonized

with the AFI Regional SUPPs contained in ICAO Doc 7030.




COMMENTS BY ICAO:


Auditee:

Audit Period: 20/11/2006 - 28/11/2006

APPENDIX 1-7-02

ANS/02GHANA



7.091;

DOCUMENT REFERENCE:


finding.


FINDING:

In accordance with regional air navigation agreements, the GCAA is responsible for the provision of air navigation

services (ANS) within the Accra Flight Information Region (FIR), which includes the high seas, airspace of Benin,

Equatorial Guinea (partly), Ghana, Sao Tome (partly), and Togo. This includes the provision of: ATS; aeronautical

telecommunications; aeronautical information services; meteorological services for international air navigation; and

aeronautical search and rescue. However, no formal coordination mechanism has been established or implemented between

Ghana and the other member States of the Accra FIR to ensure that their regulations are harmonized.

RECOMMENDATION:

The GCAA should ensure that formal coordination procedures are established between Ghana and Accra FIR member

States in order to achieve and maintain a high level of harmonization of their respective regulations.




COMMENTS BY ICAO:


Auditee:

Audit Period: 20/11/2006 - 28/11/2006

APPENDIX 1-7-03

ANS/03GHANA



7.103; 7.105;

DOCUMENT REFERENCE:


finding.


FINDING:

Ghana has implemented ICAO airspace classification within the Accra FIR in conformance with ICAO Annex 11,

including Class F airspace in the oceanic part of the FIR. The CARs, Part 19 (Rules of the Air) and the airspace

classification published in the AIP of Ghana do not reflect the two-way radio communications requirement for visual flight

rules (VFR) flights Class E, Class F and Class E airspace in accordance with the AFI Regional SUPPs contained in ICAO

Doc 7030. Furthermore, although the Accra Oceanic FIR is situated at the Atlantic Ocean Interface between the AFI, North

Atlantic and South American Regions (Area of Routing AR-2), Ghana is not involved in the regional/interregional

implementation activities carried out by the established informal meetings for the improvement of ATS over the South

Atlantic (SAT Group).

RECOMMENDATION:

The GCAA should:

a) ensure that Ghana airspace classification is harmonized with AFI Regional SUPPs contained in ICAO Doc 7030 in

respect of two-way communication requirement in Classes E, F and G airspace;

b) address the replacement of Class F airspace portions through the implementation of a higher classification of airspace;

and

c) participate in regional/interregional implementation activities aiming at improving the provision of ANS over the high

seas airspace.




COMMENTS BY ICAO:


Auditee:

Audit Period: 20/11/2006 - 28/11/2006

APPENDIX 1-7-04

ANS/04GHANA



7.133;

DOCUMENT REFERENCE:


finding.


FINDING:

The GCAA has embarked in 2004 and 2005 on a programme of upgrading and expansion of aeronautical communications

networks within the Accra FIR using satellite technology (very small aperture terminals [VSAT]), including fixed

communications with neighbouring States/FIRs and extended very high frequency (VHF) radio coverage within the FIR.

However, a number of VSAT links have not yet been improved or implemented in order to fully meet ICAO Annex 11

requirements for fixed communications between the Accra FIR and adjacent States/FIR. Furthermore, air-ground

communication requirements are not clearly established with respect to the provision of flight information services to

flights operated under VFR.

RECOMMENDATION:

The GCAA should ensure that ICAO Annex 11 requirements for fixed communications between the Accra FIR and

adjacent States/FIR are implemented in an efficient manner, in coordination with adjacent States/FIRs, and that air-ground

communication requirements with respect to the provision of flight information service to flights operated under VFR are

clearly established.




COMMENTS BY ICAO:


Auditee:

Audit Period: 20/11/2006 - 28/11/2006

APPENDIX 1-7-05

ANS/05GHANA



7.161; 7.163; 7.165; 7.167; 7.169; 7.171; 7.173; 7.175;

7.177; 7.179; 7.181; 7.183; 7.185; 7.189;

DOCUMENT REFERENCE:


finding.

CE-1 CE-2 X CE-3 X CE-4 CE-5 X CE-6 X CE-7 X CE-8

FINDING:

The CARs, Part 24 establishes a requirement for the implementation of ATS safety management programmes. However,

although the GCAA has already developed guidelines to implement such programmes, systematic and appropriate safety

management programmes have not yet been implemented by the GCAA in conformance with the provisions contained in

ICAO Annex 11, Chapter 2.

RECOMMENDATION:

The GCAA should ensure that ATS safety management programmes are implemented in conformance with the provisions

contained in ICAO Annex 11, Chapter 2.




COMMENTS BY ICAO:


Auditee:

Audit Period: 20/11/2006 - 28/11/2006

APPENDIX 1-7-06

ANS/06GHANA



7.201; 7.203; 7.205; 7.207; 7.209; 7.211; 7.213; 7.215;

7.219; 7.221; 7.225; 7.227; 7.229; 7.231; 7.233; 7.241;

7.243; 7.245; 7.253; 7.255;

DOCUMENT REFERENCE:


finding.

CE-1 CE-2 X CE-3 X CE-4 X CE-5 CE-6 X CE-7 X CE-8 X

FINDING:

The GCAA has not established regulations and procedures applicable to visual and instrument f l ight procedures

(Procedures for Air Navigation Services-Aircraft Operations [PANS-OPS]). There is not a formal agreement with the

contracting agency (Jeppesen) clearly establishing GCAA requirements and oversight functions, and the procedures

developed by the PANS-OPS service provider are not subject to GCAA approval prior to their publication. Furthermore,

the GCAA does not retain all procedure design documentation so as to allow any data anomalies or errors found during the

production, maintenance or operational use of the procedure to be corrected. In addition, some applicable procedures have

not yet been developed and published for instrument runways in accordance with the provisions contained in ICAO Doc

7474 (AFI Air Navigation Plan).

RECOMMENDATION:

The GCAA should:

a) establish and promulgate PANS-OPS regulations and procedures to be applicable in Ghana and ensure that they are in

compliance with ICAO PANS-OPS (Doc 8168);

b) establish PANS-OPS approval procedures;

c) ensure that all procedure design documentation is retained so as to allow any data anomalies or errors found during the

production, maintenance or operational use of the procedures to be corrected; and

d) develop and publish procedures, as applicable, for instrument runways in accordance with the provisions contained in

ICAO Doc 7474 (AFI Air Navigation Plan).




COMMENTS BY ICAO:


Auditee:

Audit Period: 20/11/2006 - 28/11/2006

APPENDIX 1-7-07

ANS/07GHANA



7.321; 7.323; 7.363;

DOCUMENT REFERENCE:


finding.

CE-1 CE-2 CE-3 X CE-4 CE-5 X CE-6 CE-7 CE-8

FINDING:

The GCAA has contracted the production of aeronautical charts to a private agency. However, a cartography service has

not been established to address matters pertaining to ICAO Annex 4 provisions, including safety oversight functions. In

addition, there is no formal coordination between the GCAA and the Ghana Surveys Department to ensure that the charts

and relief data used for the development of aeronautical charts and PANS-OPS procedures are reliable and accurate.

RECOMMENDATION:

The GCAA should establish safety oversight functions for the cartography service in order to address matters pertaining to

ICAO Annex 4 provisions. In addition, the GCAA should ensure that a formal coordination is established with the Ghana

Surveys Department to ascertain that the charts and relief data used for the development of aeronautical charts and

PANS-OPS procedures are reliable and accurate.




COMMENTS BY ICAO:


Auditee:

Audit Period: 20/11/2006 - 28/11/2006

APPENDIX 1-7-08

ANS/08GHANA



7.511; 7.517; 7.529; 7.531; 7.533;

DOCUMENT REFERENCE:


finding.

CE-1 CE-2 CE-3 X CE-4 CE-5 CE-6 X CE-7 X CE-8

FINDING:

Ghana has established a rescue and coordination centre (RCC) and rescue and coordination sub-centres (RSCs) within the

Accra search and rescue region (SRR). However, it has not established a joint RCC to coordinate aeronautical and

maritime search and rescue (SAR) operations. Furthermore, cooperation agreements have been signed with Burkina Faso

and Togo; however, additional cooperation agreements with neighbouring States have not yet been concluded. In addition,

the GCAA has not establised SAR training requirements to ensure availabili ty of sufficient work force skil led in

coordination and operational functions.

RECOMMENDATION:

The GCAA should establish:

a) a joint RCC to coordinate aeronautical and maritime SAR operations;

b) cooperation agreements with all its neighbouring States; and

c) SAR training requirements to ensure that a sufficient workforce, skilled in coordination and operational functions, is

available.




COMMENTS BY ICAO:


Auditee:

Audit Period: 20/11/2006 - 28/11/2006

APPENDIX 1-7-09

ANS/09GHANA



7.033; 7.037; 7.061; 7.073; 7.261; 7.265; 7.267; 7.269;

7.271; 7.273; 7.275; 7.277; 7.279; 7.281; 7.283; 7.285;

7.287; 7.303; 7.325; 7.327; 7.329; 7.331; 7.333; 7.335;

7.337; 7.339; 7.341; 7.343; 7.351; 7.353; 7.355; 7.373;

7.383; 7.385; 7.387; 7.417; 7.419; 7.421; 7.423; 7.425;

7.505;7.503;7.501;7.499;7.495;7.493;

7.491;7.489;7.487;7.451;7.437;7.431;7.429;7.427;

DOCUMENT REFERENCE:


finding.

CE-1 CE-2 CE-3 X CE-4 X CE-5 X CE-6 X CE-7 X CE-8 X

FINDING:

The GCAA, through its Directorate of Safety Regulations, is in the process of establishing and implementing a safety

oversight system for ensuring the effective implementation of safety-related procedures in the fields of ANS. However,

only ATS and aeronautical telecommunications are currently covered. Related inspections are conducted by one ATS and

one engineering inspector who use dedicated audit handbooks and take follow-up action on the inspection reports, as

required in order to solve identified deficiencies. However, while the training programme developed by the GCAA to

suppor t the ANS safe ty overs igh t implementa t ion process has no t ye t been implemented and comple ted , the

Director-General of the GCAA has already accredited some ANS technical staff as inspectors. Furthermore, the trends in

the industry are not monitored to accommodate new requirements when necessary.

RECOMMENDATION:

The GCAA should:

a) establish and implement a safety oversight system for ensuring the effective implementation of safety-related

procedures in all functional air navigation areas;

b) ensure that the qualification process, including training requirements for ANS inspectors, is clearly defined and that

the established requirements are implemented prior to the assignment of safety oversight functions to the ANS

inspectorate staff; and

c) monitor the trends in the industry to accommodate new requirements (i.e. staffing, training and working environment)

when necessary.




COMMENTS BY ICAO:


Auditee:

Audit Period: 20/11/2006 - 28/11/2006

APPENDIX 1-7-10

ANS/10GHANA



7.019;

DOCUMENT REFERENCE:


finding.


FINDING:

The AIP of Ghana is published in three parts, in conformance with ICAO Annex 15, Chapter 4 and Appendix 1, which are

included in a single volume. However, the AIP contains discrepancies with respect to applicable air navigation regulations,

procedures and practices, as well as differences from ICAO SARPs.

RECOMMENDATION:

The GCAA should ensure that:

a) the Ghana CARs are reflected in the AIP of Ghana without discrepancies; and

b) the AIP of Ghana is kept current and the safety critical information published therein is accurate and updated in an

efficient and timely manner.




COMMENTS BY ICAO:


Auditee:

Audit Period: 20/11/2006 - 28/11/2006

APPENDIX 1-7-11

ANS/11GHANA



7.153; 7.159;

DOCUMENT REFERENCE:


finding.


FINDING:

The GCAA has not developed updated ATS contingency plans applicable in the event of disruption or potential disruption

of ATS or related supporting services.

RECOMMENDATION:

The GCAA should ensure that ATS contingency plans are developed and updated as necessary for implementation in the

event of disruption or potential disruption of ATS or related supporting services, in conformance with ICAO Annex 11 and

Doc 9426 provisions.




COMMENTS BY ICAO:


Auditee:

Audit Period: 20/11/2006 - 28/11/2006

APPENDIX 1-7-12

ANS/12GHANA



7.465;

DOCUMENT REFERENCE:


finding.


FINDING:

The Ghana Meteorology Agency (GMA) offices do not issue wind shear warnings for aerodromes such as Accra Kotoka

International Airport, where wind shear is considered as a safety factor, in conformance with ICAO Annex 3, Part I.

RECOMMENDATION:

The GCAA should ensure that wind shear warnings for aerodromes, where wind shear is considered as a safety factor, are

issued by the aeronautical meteorology service provider in conformance with ICAO Annex 3, Part I.




COMMENTS BY ICAO:


Auditee:

Audit Period: 20/11/2006 - 28/11/2006

APPENDIX 1-7-13

ANS/13GHANA



7.109; 7.117;

DOCUMENT REFERENCE:


finding.


FINDING:

The GCAA has implemented one area navigation (RNAV)/required navigation performance (RNP) 10 route (UM 114)

following a satisfactory pre-implementation safety assessment, in coordination with all the States involved in the

implementation. In addition, the GCAA has developed a National Safety Plan within the framework of AFI reduced

vertical separation minimum (RVSM) programme and submitted it to the AFI Regional Monitoring Agency (ARMA),

which is tasked with the performance of related pre-implementation and post-implementation safety assessments.

However, there are no formal arrangements between the GCAA and the ARMA with respect to the provision of periodic

safety assessments for RNP and RVSM operations.

RECOMMENDATION:

The GCAA should ensure that mechanisms for the monitoring of navigation performance and periodic safety assessment

are established for RNP and RVSM operations. In addition, the GCAA should formalize cooperative arrangements with

respect to periodic safety assessments for RNP and RVSM operations with the ARMA or any other relevant organization.




COMMENTS BY ICAO:


Auditee:

Audit Period: 20/11/2006 - 28/11/2006

APPENDIX 1-7-14

ANS/14GHANA



7.045; 7.289; 7.345; 7.395; 7.507;

DOCUMENT REFERENCE:


finding.


FINDING:

The GCAA has established a formal mechanism for the review and elimination of deficiencies identified within the

framework of the AFI Planning and Implementation Regional Group (APIRG); however, there is no adequate coordination

with Ghana adjacent Sta tes /FIRs to ensure the resolut ion of some cr i t ical def ic iencies ( i .e . aeronaut ica l f ixed

telecommunications).

RECOMMENDATION:

The GCAA should ensure that adequate coordination with Ghana adjacent States/FIRs is established in order to resolve

ANS-related deficiencies identified within the framework of the APIRG or reported by other relevant sources of

information.




COMMENTS BY ICAO:


Auditee:

Audit Period: 20/11/2006 - 28/11/2006

APPENDIX 1-7-15

ANS/15GHANA



7.301;

DOCUMENT REFERENCE:


finding.


FINDING:

According to the terms of reference for AIS technical staff defined in the Aeronautical Information Services Procedures

Handbook , the AIS Section of the GCAA is tasked with the following functions: ATS reporting; telecommunication

operations; statistics and billing/collecting; and processing of operators' over flight and landing requests. However, the

tasks and responsibilities for each ANS functional area have not been clearly established, and written terms of reference

for the technical staff involved at the service provider's level have not been developed.

RECOMMENDATION:

The GCAA should ensure that:

a) tasks and responsibilities for each ANS functional area (i.e. AIS, ATS reporting office and telecommunication

operations) are clearly defined; and

b) written terms of reference for the technical staff involved in AIS, ATS and telecommunications are developed

accordingly at the service provider's level.




COMMENTS BY ICAO:


Auditee:

Audit Period: 20/11/2006 - 28/11/2006

APPENDIX 1-7-16

ANS/16GHANA



7.031;

DOCUMENT REFERENCE:


finding.


FINDING:

The organizational structure of the GCAA Air Traffic Services Department establishes the lines of accountability and

responsibility with respect to ATS, AIS and SAR. However, AIS and SAR are shown as part of ATS, and there is no clear

indication as to the offices responsible for aeronautical charts (MAP), PANS-OPS and coordination of MET-related

matters.

RECOMMENDATION:

The Director-General of the GCAA should ensure that i ts organizational structure clearly establishes the l ines of

accountability and responsibility with respect to all ANS services, including the offices responsible for MAP, PANS-OPS

and coordination of MET-related matters.




COMMENTS BY ICAO:


Auditee:

Audit Period: 20/11/2006 - 28/11/2006

APPENDIX 1-8-01

AGA/01GHANA


AERODROMES

8.083; 8.087; 8.361; 8.407;

DOCUMENT REFERENCE:


finding.

CE-1 CE-2 X CE-3 CE-4 CE-5 X CE-6 X CE-7 CE-8 X

FINDING:

The GCAA has established a legislative and regulatory framework for the certification of its aerodromes. However, to date,

only one of its designated aerodromes, the Kotoka International Airport in Accra has been certified. Furthermore, the

requirement for aerodromes to establish a formal safety management system (SMS) has only been partially implemented.

In addition, the aerodrome manual approved for the Kotoka International Airport does not include detailed operating

procedures and particulars of the facilities, equipment, personnel and procedures for meeting the requirements for

aerodrome services to be provided, such as RFF, bird hazard reduction and removal of disabled aircraft. Although a formal

mechanism exists by which regulatory staff should evaluate the competence and experience of aerodrome staff, the

associated procedures and guidance material have not yet been developed and made available to the industry. The certified

status of an aerodrome is not currently published in the AIP of Ghana.

RECOMMENDATION:

The GCAA should fully implement the certification process for its aerodromes, including the requirement for SMS, and

publish the certified status of each aerodrome in the AIP of Ghana. In addition, the GCAA should review the contents of

the Kotoka International Airport manual in compliance with the national requirements provided for in the CARS, Part 14

(Implementing standards). Furthermore, the GCAA should develop enhanced procedures and guidance material for both

regulatory staff and the industry to facilitate the assessment of competence and experience of aerodrome staff.




COMMENTS BY ICAO:


Auditee:

Audit Period: 20/11/2006 - 28/11/2006

APPENDIX 1-8-02

AGA/02GHANA


AERODROMES

8.001; 8.303; 8.381; 8.383;

DOCUMENT REFERENCE:


finding.


FINDING:

The GCAA has developed and promulgated the CARs, Part 14 for the regulation and certification of its designated

aerodromes in order to implement the provisions of ICAO Annex 14, Volume I. However, the GCAA has not established a

clear policy as regards ICAO Recommended Practices, some of which have been upgraded to a national standard but are in

conflict with ICAO less restrictive Standards. In addition, although there are no civil heliports in Ghana, the GCAA has

developed the CARs, Part 14, Volume 2 containing provisions for the design and operation of heliports. However, it has

not yet been approved by the Parliament and come into force.

RECOMMENDATION:

The GCAA should adopt a clear policy as regards ICAO Recommended Practices for the regulation and certification of

aerodromes to avoid conflicting requirements. In addition, the GCAA should expedite the approval and promulgation of

the CARs, Part 14, Volume 2 concerning the design and operation of civil heliports.




COMMENTS BY ICAO:


Auditee:

Audit Period: 20/11/2006 - 28/11/2006

APPENDIX 1-8-03

AGA/03GHANA


AERODROMES

8.031; 8.033; 8.039; 8.049;

DOCUMENT REFERENCE:


finding.

CE-1 CE-2 CE-3 X CE-4 X CE-5 CE-6 CE-7 CE-8

FINDING:

The GCAA Aerodrome Safety and Standards (ASAS) Section is tasked with aerodrome certification and surveillance

activities. However, this section relies on personnel and inputs from other sections within the Safety Regulations

Department. The functions and responsibilities of the ASAS are not clearly defined, and the post of Deputy Director

heading the section has not been filled. Currently, there is a lack of direction and coordination of the safety oversight

activities. Furthermore, the three technical officers of the ASAS are from a limited range of professional backgrounds.

Although some technical expertise is available from other GCAA areas to assist in the ongoing aerodrome certification

process, the effectiveness of the safety oversight function is hampered by the lack of staff with wider professional

backgrounds, such as aerodrome operations. In addition, the certification process is still in its early stages, and in view of

the demanding nature of continuing effective safety oversight activities and the need for enhanced training to cover all the

disciplines involved in the certification process, the current staffing level is unlikely to meet the requirements.

RECOMMENDATION:

The GCAA should review the current organization and staffing of the ASAS to ensure that aerodrome safety oversight

activities are integrated and co-ordinated in an effective manner within the organization. The review should ensure that

sufficient technical regulatory staff of the necessary disciplines, competence and experience are readily available to form a

cohesive team, to enable the GCAA to implement its aerodrome certification programme and carry out its safety oversight

function effectively.




COMMENTS BY ICAO:


Auditee:

Audit Period: 20/11/2006 - 28/11/2006

APPENDIX 1-8-04

AGA/04GHANA


AERODROMES

8.051;

DOCUMENT REFERENCE:


finding.

CE-1 CE-2 CE-3 CE-4 X CE-5 CE-6 CE-7 CE-8

FINDING:

The GCAA has established a training policy and programme for its aerodrome regulatory staff; however, the scope of the

training requirements does not include specialized areas, such as human factors, aeronautical studies and risk assessment.

In addition, there is no provision for minimum initial mandatory training, including on-the-job-trainig (OJT), to become a

qualified and accredited aerodrome inspector, nor are there requirements to access different levels of the inspection

functions.

RECOMMENDATION:

The GCAA should review the scope of the training requirements and programme for aerodrome regulatory staff and

inspectors to include training in specialized areas, such as human factors, aeronautical studies and risk assessment, as well

as minimum initial mandatory training, including OJT, in order to ensure that they become qualified and accredited

aerodrome inspectors and are competent to exercise their safety oversight responsibilities.




COMMENTS BY ICAO:


Auditee:

Audit Period: 20/11/2006 - 28/11/2006

APPENDIX 1-8-05

AGA/05GHANA


AERODROMES

8.063; 8.069; 8.331;

DOCUMENT REFERENCE:


finding.


FINDING:

The GCAA has developed a number of documents as guidance material for its technical staff and to assist the industry in

meeting its national requirements. However, this material does not cover all disciplines involved in the certification

process of aerodromes, and its scope does not include certain areas, such as aeronautical studies, risk assessment and bird

strike hazard, among others.

RECOMMENDATION:

The GCAA should expedite the development of additional guidance material for its technical staff and to assist the

industry in meeting its national requirements in various disciplines involved in the certification process of aerodromes,

including aeronautical studies, risk assessment and bird strike hazard, among others.




COMMENTS BY ICAO:


Auditee:

Audit Period: 20/11/2006 - 28/11/2006

APPENDIX 1-8-06

AGA/06GHANA


AERODROMES

1.027; 8.099; 8.367; 8.369; 8.371; 8.373; 8.375; 8.377;

DOCUMENT REFERENCE:


finding.

CE-1 CE-2 X CE-3 CE-4 X CE-5 X CE-6 CE-7 X CE-8

FINDING:

The safety oversight function includes the review and approval of exemptions where non-conformance to established

requirements is deemed necessary and approved by the regulatory authority. Such exemptions are normally based on

aeronautical studies and/or risk assessments. However, the GCAA has not issued a formal policy stating the circumstances

and rationale under which aeronautical studies and/or risk assessments may be used. In addition, limited guidance has been

made available to aerodrome operators and regulatory staff on risk assessment principles and processes, and ASAS staff

has not received formal training in the development, evaluation and application of aeronautical studies and/or risk

assessments. Furthermore, there is no clear process by which non compliances of operational significance are processed

and notified to air operators and other interested parties.

RECOMMENDATION:

The GCAA should promulgate a policy to define the circumstances under which an aeronautical study and/or risk

assessment may be used to support the application of a non-conformance or non-adherence to published requirements. The

GCAA should develop comprehensive guidance on the development, evaluation and use of aeronautical studies and risk

assessments and establish appropriate training requirements for its regulatory technical staff and aerodrome inspectors. In

addition, the GCAA should establish a clear process for the assessment of exceptions and publish the outcomes in the AIP

of Ghana.




COMMENTS BY ICAO:


Auditee:

Audit Period: 20/11/2006 - 28/11/2006

APPENDIX 1-8-07

AGA/07GHANA


AERODROMES

8.135;

DOCUMENT REFERENCE:


finding.


FINDING:

The GCAA has not established a requirement for the implementation of a quality system in order to ensure the accuracy,

integrity and protection of aeronautical data reported by the aerodrome operator throughout the data transfer process.

RECOMMENDATION:

The GCAA should establish a requirement for the implementation of a quality system in order to ensure the accuracy,

integrity and protection of aeronautical data reported by the aerodrome operator throughout the data transfer process.




COMMENTS BY ICAO:


Auditee:

Audit Period: 20/11/2006 - 28/11/2006

APPENDIX 1-8-08

AGA/08GHANA


AERODROMES

8.137; 8.139;

DOCUMENT REFERENCE:


finding.


FINDING:

The GCAA has not established criteria and associated industry guidelines to regulate the use of a pavement by an aircraft

with an aircraft classification number (ACN) higher than the reported pavement classification number (PCN). In addition

the published pavement bearing strengths are not current and do not reflect the real status of the runway pavements.

RECOMMENDATION:

The GCAA should establish criteria and associated industry guidelines to regulate the use of a pavement by an aircraft with

an ACN higher than the reported PCN. In addition, the GCAA should ensure that the reported pavement bearing strengths

of runways are current and reflect the real status of the runway pavements.




COMMENTS BY ICAO:


Auditee:

Audit Period: 20/11/2006 - 28/11/2006

APPENDIX 1-8-09

AGA/09GHANA


AERODROMES

8.143; 8.145; 8.147; 8.255; 8.257;

DOCUMENT REFERENCE:


finding.

CE-1 CE-2 X CE-3 CE-4 CE-5 CE-6 CE-7 X CE-8

FINDING:

The GCAA does not ensure that all aerodrome operators monitor and report the condition of the movement areas and related

facilities and comply with national requirements for the measurement and reporting of runway friction characteristics, in

particular, to determine friction levels for maintenance planning purposes; to assess when a runway may become slippery

when wet or under unusual conditions; and to report the type of friction measuring device used.

RECOMMENDATION:

The GCAA should ensure that all aerodrome operators monitor and report the condition of the movement areas and related

facilities and comply with the national requirements for the measurement and reporting of runway friction characteristics,

including the type of friction measuring device used. The GCAA should also ensure that aerodrome operators establish a

maintenance programme that achieves good friction characteristics and low rolling resistance on runways.




COMMENTS BY ICAO:


Auditee:

Audit Period: 20/11/2006 - 28/11/2006

APPENDIX 1-8-10

AGA/10GHANA


AERODROMES

8.163; 8.165;

DOCUMENT REFERENCE:


finding.

CE-1 CE-2 X CE-3 CE-4 CE-5 CE-6 X CE-7 CE-8

FINDING:

The GCAA does not ensure the provision of runway end safety areas (RESAs) at all aerodromes in compliance with

national requirements and has no formal mechanism to ensure that the runway surroundings are safe for use by aircraft in

the event of an aircraft overrunning or undershooting the runway. In addition, the CARs, Part 14 contains two different and

conflicting requirements for the RESA, reflecting both the ICAO Standard and Recommended Practice.

RECOMMENDATION:

The GCAA should ensure the provision for RESAs at aerodromes and where this requirement is not implemented, conduct

a formal risk assessment and apply mitigating measures, in order to ensure that the runway surroundings are safe for use by

aircraft in the event of an aircraft overrunning or undershooting the runway. In addition, the GCAA should adopt a unique

requirement for RESAs in the CARs, Part 14.



COMMENTS BY ICAO:

The corrective action plan submitted by the State partially addresses this ICAO finding and recommendation. The State has

not addressed the two different and conflicting requirements for RESAs in CARs, Part 14.

Auditee:

Audit Period: 20/11/2006 - 28/11/2006

APPENDIX 1-8-11

AGA/11GHANA


AERODROMES

8.179;

DOCUMENT REFERENCE:


finding.


FINDING:

The GCAA does not ensure that aerodromes have monitoring systems to ensure lighting system reliability and indicate any

fault which may affect control functions.

RECOMMENDATION:

The GCAA should ensure that aerodromes have monitoring systems to ensure lighting system reliability and indicate any

fault which may affect control functions.




COMMENTS BY ICAO:


Auditee:

Audit Period: 20/11/2006 - 28/11/2006

APPENDIX 1-8-12

AGA/12GHANA


AERODROMES

8.205;

DOCUMENT REFERENCE:


finding.


FINDING:

The GCAA does not ensure that an aerodrome operator’s plan for lighting, signs and markings is integrated as a whole into

the aerodrome’s runway incursion and collision avoidance strategy, taking account of different aerodrome traffic

intensities and visibility conditions.

RECOMMENDATION:

The GCAA should ensure that an aerodrome operator’s plan for lighting, signs and markings is integrated as a whole into

the aerodrome’s runway incursion and collision avoidance strategy, taking account of different aerodrome traffic

intensities and visibility conditions.




COMMENTS BY ICAO:


Auditee:

Audit Period: 20/11/2006 - 28/11/2006

APPENDIX 1-8-13

AGA/13GHANA


AERODROMES

8.365;

DOCUMENT REFERENCE:


finding.


FINDING:

The GCAA does not require aerodrome operators to ensure that organizations performing activities at the aerodrome

comply with the safety requirements laid down by the aerodrome operator.

RECOMMENDATION:

The GCAA should require aerodrome operators to ensure that organizations performing activities at the aerodrome comply

with the safety requirements laid down by the aerodrome operator.




COMMENTS BY ICAO:


Auditee:

Audit Period: 20/11/2006 - 28/11/2006

APPENDIX 1-8-14

AGA/14GHANA


AERODROMES

8.013; 8.411; 8.413;

DOCUMENT REFERENCE:


finding.

CE-1 X CE-2 CE-3 CE-4 CE-5 CE-6 CE-7 CE-8 X

FINDING:

The GCAA has established an inspection programme for the continued survei l lance of aerodromes that is being

implemented, although all designated aerodromes have not yet been certified. However, the procedures for dealing with the

deficiencies identified during aerodrome inspections until their resolution are not clearly defined. In addition, the

enforcement actions in the event of non-conformance with the certification requirements or an unresolved safety concern

include the revocation or cancellation of the certificate; however, i t does not include the imposition of operating

restrictions.

RECOMMENDATION:

The GCAA should clearly define the procedures for dealing with identified aerodrome deficiencies until their resolution.

In addition, the GCAA should formally include in its set of enforcement actions the imposition of operating restrictions in

the event of non-conformance with the certification requirements or an unresolved safety concern.




COMMENTS BY ICAO:


Auditee:

Audit Period: 20/11/2006 - 28/11/2006

APPENDIX 1-8-15

AGA/15GHANA


AERODROMES

8.151; 8.321;

DOCUMENT REFERENCE:


finding.


FINDING:

The GCAA has an aircraft removal kit and related operating procedures have been developed for RFF personnel. However,

it does not ensure that all designated aerodromes have formal plans for the removal of disabled aircraft, including

arrangements for coordinators to be designated, the rapid availability and deployment of salvage and removal equipment

between aerodromes, and the protection of evidence, custody and the removal of aircraft in conformance with ICAO

Annex 13. In addition, the GCAA has not published information concerning aerodromes' capability to remove disabled

aircraft.

RECOMMENDATION:

The GCAA should ensure that all designated aerodromes have formal plans for the removal of disabled aircraft, including

arrangements for coordinators to be designated, the rapid availability and deployment of salvage and removal equipment

between aerodromes, and the protection of evidence, custody and the removal of aircraft in conformance with ICAO

Annex 13. In addition, the GCAA should publish information concerning aerodromes' capability to remove disabled

aircraft.




COMMENTS BY ICAO:


Auditee:

Audit Period: 20/11/2006 - 28/11/2006

APPENDIX 1-8-16

AGA/16GHANA


AERODROMES

8.345;

DOCUMENT REFERENCE:


finding.


FINDING:

The GCAA does not ensure that aerodrome operators restrict the operation of personnel and vehicles during low visibility

operations.

RECOMMENDATION:

The GCAA should ensure that aerodrome operators restrict the operation of personnel and vehicles during low visibility

operations.




COMMENTS BY ICAO:


APPENDIX 2

CRITICAL ELEMENTS OF A SAFETY OVERSIGHT SYSTEMLACK OF EFFECTIVE IMPLEMENTATION (%)

29.44

36.07

45.1341.99

57.02

33.67

43.28

47.46

14.81

35.37

43.52 44.44

22.88

35.05

38.67 39.53

0

10

20

30

40

50

60

70

80

90

100

Primary AviationLegislation

Specific OperatingRegulations

Civil Aviation Systemand Safety Oversight

Functions

Qualification andTraining of Technical

Staff

Procedures andTechnical Guidance

Licensing andCertificationObligations

SurveillanceObligations

Resolution of SafetyConcerns

Global: (62) Audited States: 41.75% Audit of: GHANA 34.28%

APPENDIX 3

APPENDIX 3-1-1

CORRECTIVE ACTION PLAN PROPOSED BY GHANA RELATED TO PRIMARY AVIATION LEGISLATION

AND CIVIL AVIATION REGULATIONS

AUDIT FINDING LEG/01

The Legal Services Department Procedures Manual of the Ghana Civil Aviation Authority (GCAA) contains procedures to be followed for the review of the Ghana Civil Aviation Regulations (CARs), subsequent to an amendment of an ICAO Annex. The Constitution of the Republic of Ghana requires the amendments to the CARs to be laid before Parliament for a period of twenty-one days prior to coming into force. This is undertaken under cover of a submission known as a Legal Instrument (LI), and formal notification is given by the Office of Parliament once the House has passed the LI. However, with the processing of LI 1824, a reference to Chapters 1 and 2 as part thereto was not included in the schedule, thereby putting the validity of these chapters in doubt. Chapter 2 includes a clause repealing and replacing the entire Part 2 of the CARs. No such clause is included in Chapter 1, with the effect that there is now both a Chapter 1 and a Part 1 of the CARs in force dealing with the same requirements. In addition, these CARs do not provide for the implementation of all Annex 1 provisions.

STATE’S COMMENTS AND OBSERVATIONS∗

The CAA does not agree with above finding. Legislative Instruments (LI) are discussed at Parliament, first at the Subsidiary legislative Committee level (the Committee is made up of seasoned lawyers who are members of Parliament) and eventually, debated by the full House of Parliament. This procedure was followed by Parliament before L.I. 1824 was approved and passed by the Honourable Members of Parliament. The said LI 1824 as approved by Parliament included Chapters 1 and 2. It is only the approved text from Parliament which is forwarded by the Ministry of Justice and Office of the Attorney General to the Government Printer (Assembly Press) for printing. Copies of the approved document are always kept in the Library of Parliament for their records and any necessary verification. Following printing, the GCAA is informed to collect the documents. Chapter 2 of L.I. 1824 only repealed Part 2 of L.I. 1818 (in respect of personnel licensing) and not L.I. 1824. Chapter 1 of LI 1824 and Part 1 of LI 1818 do not deal with the same requirements. Chapter 1 of LI 1824 deals with the General Policies, Procedures and Definitions applicable to LI 1824. Similar provisions and more as applicable to Regulations contained in LI 1818 are provided in Part 1 of LI 1818. A comparison of the contents of the two shows the differences.

∗ Text reproduced as submitted by Ghana

APPENDIX 3-1-1 (CONT.)



CORRECTIVE ACTION(S) PROPOSED∗ ACTION OFFICE

ESTIMATED IMPLEMENTATION

DATE(S) i. No corrective action is proposed as the procedures

followed by the Authority for the promulgation of LI 1818 and LI 1824 were in accordance with Constitutional requirements, and the prior consent of the Minister.

ii. The Director-General of the GCAA in consultation

with the office of the Minister of Aviation shall continue to follow the natural procedures for passing legislation. He shall ensure the correctness of the amendments to the CARs to be submitted to Parliament for consideration.

Legal

30 June 2008


APPENDIX 3-1-2




The Legal Services Department Procedures Manual contains procedures to be followed for the verification of compliance of the CARs with ICAO Annex provisions, subsequent to an ICAO Annex amendment, and includes related technical coordination and identification and notification of differences to ICAO. The prescribed process involves reference to the user department and a review by a technical review committee. However, this process has not been implemented and adhered to, and the minutes or recommendations of the technical review committee are not available.


The CAA agrees with the finding of the ICAO audit team. The Technical Review Committee (TRC) had met once following its inauguration. Previous mode of dealing with amendments was by the comments of user departments which were co-ordinated before approval of the Director-General. The TRC has subsequently held five meetings and has an effective system of recording minutes.



DATE(S) The Technical Review Committee shall hold regular meetings and circulate minutes to the members as well as Senior Management. Records of such meetings shall be kept.

Technical Review

Committee

Already implemented


APPENDIX 3-1-3




The Ghana Civil Aviation Act, 2004 (Act 678), Article 3(1) establishes that one of the functions of the GCAA is the responsibility to ensure compliance with the Conventions, Annexes, Protocols and any other relevant ICAO SARPs. However, Article 9.V(7) of the Act only requires the Director-General of the GCAA to monitor and enforce compliance with ICAO Annexes 1, 6 and 8 and the Technical Instructions for the safe transport of dangerous goods by air. This limitation restricts the scope of action and enforcement powers of the Director-General.


The CAA agrees in part with the finding of the ICAO audit team, but wishes to put on record that this deficiency had already been identified by the CAA, and as such formed part of proposals submitted to the Ministry of Justice and Office of the Attorney General on 8th November 2006 for the amendments to Act 678. A copy of the said letter and the proposals for amendment were made available to the Audit Team.



DATE(S) Ghana is in the process of revising the Civil Aviation Act to extend the responsibility of the Director General to include the monitoring and enforcement of compliance to all Annexes of the Chicago Convention.

Technical Review

Committee/ Legal

Department

Parliament

31 December 2007


APPENDIX 3-2-1

CORRECTIVE ACTION PLAN PROPOSED BY GHANA RELATED TO CIVIL AVIATION ORGANIZATION

AUDIT FINDING ORG/01

Repeal of Law 151 by the Ghana Civil Aviation Act, 2004 (Act 678) was implemented to provide for the transition of the separation of functions of the GCAA as both regulator and service provider to solely that of regulator. However, to date, this transition has not been achieved and does not provide for a clear distinction of responsibilities, creating a potential conflict of interests.


The CAA agrees with the finding of the ICAO audit team.



DATE(S) The Ministry of Aviation shall implement the separation of GCAA from GACL

Ministry of Aviation

1 January 2007

The GCAA and GACL shall work together to implement the separation of the functions of the GCAA as regulator from GACL as service provider.

GCA GACL

31 March 2007


APPENDIX 3-2-2



The GCAA Human Resources Management Policy and Administrative Procedures Manual contains the functions and responsibilities of the Safety Regulations Department as well as job descriptions for management staff and aviation safety inspectors. However, the functions and responsibilities of the lower level departments and sections have not been clearly defined.


GCAA agrees with the Audit Finding



DATE(S) GCAA shall cleary define all the functions and responsibilities of each department and section and include same in the HR Management Policies and Administrative Procedures Manual.

DHR/ RESPECTIVE

HODs

31 March 2007


APPENDIX 3-2-3



The Ghana Meteorological Agency (GMA) under the Ministry of Communications and Technology is the sole authority responsible for meteorological services (MET) - related matters in Ghana, including the provision of MET for international air navigation in conformance with ICAO Annex 3. Accordingly, a Memorandum of Understanding (MOU) was signed between the GCAA and the GMA. However, the MOU does not establish a clear separation between the regulatory functions, including safety oversight functions, and the service provision functions.


GCAA agrees with the finding of the ICAO Audit team.



DATE(S) The MOU signed between GCAA and GMA shall be amended to separate the regulatory functions including safety oversight to be exercised by GCAA and the service provision functions to be exercised by GMA

GMA/GCAA 30 September 2007


APPENDIX 3-2-4



The GCAA has established both a central and technical library for the use of GCAA personnel to access ICAO Annexes and associated guidance material and other documentation. However, various versions of publications (both in hard and soft copy format) in use by GCAA staff do not clearly indicate the validity or currency status of the documents. Furthermore, the technical library does not contain up-to-date copies of all ICAO Annexes and related guidance material. The documents stored in the archives are not marked as such, and there is no system in place to ensure the currency of design organization documentation.


GCAA agrees with the finding of the ICAO Audit team



DATE(S) GCAA shall;

1. Establish and implement a process that ensures that relevant information be readily available to staff and users.

HR

12 January 2007

2. Introduce a system that clearly identifies the latest and current versions of the annexes and other documents available to staff.

Library/Corporate Communication

12 January 2007

3 Mark uncontrolled versions of all documents as such.

Library 23 December 2006

4 establish a system of subscription with design organization to ensure currency of documentation

DSR 15 March 2007


APPENDIX 3-2-5



The GCAA has not provided adequate facilities for the Flight Operations and Aerodrome Sections to allow them to effectively accomplish their functions and duties.





DATE(S) I. GCAA shall provide adequate facilities i.e. Fax, telephone,

computer with internet service to Flight Operations and Aerodrome Sections.

HR 15 June 2007


APPENDIX 3-3-1

CORRECTIVE ACTION PLAN PROPOSED BY GHANA RELATED TO PERSONNEL LICENSING AND TRAINING

AUDIT FINDING PEL/01

The GCAA uses the services of a medical assessor; however, the reports submitted by designated medical examiners are not evaluated. In addition, there is an overlap of the functions of the medical assessor and those of the GCAA Medical Board.





DATE(S) I. The GCAA shall coordinate with medical assessors for the

evaluation and completion of medical assessments for all flight and cabin crew as well as air traffic controllers.

PEL/Medical Assessors

30 March 2007

II. LI 1824 Regulation 2.10.1 to be amended to conform with current practice by the deletion of: Evaluation of reports submitted to Aviation Medical Examiners from the Medical Board functions. The PEL office will coordinate with Legal to issue a technical directive in support of this regulation.

PEL/Legal

30 August 2007

III.The Procedures would be amended to clearly define the functions of the medical assessor and those of the GCAA Medical Board.

PEL

20 June 2007


APPENDIX 3-3-2



The GCAA has not implemented a system for the supervision and control of medical examiners.





DATE(S) I. GCAA will draw up a surveillance policy, plan and

program for Authorised Medical Examiners.


28 June 2007

II. Surveillance program will be reviewed on annual basis to ensure the full implementation of its provisions.


20 June 2007

III. Inspections will be conducted biennially to ensure full implementation of the surveillance program.

Medical Assessors

30 September 2007


APPENDIX 3-3-3



The GCAA has not implemented a system to ensure consistency and reliability of testing by the designated/delegated organizations or examiners, for written and oral examinations and to ensure that the examiners have the required qualifications for their appointment.





DATE(S) GCAA shall :

i. Coordinate with designated/delegated approved training organizations and examiners to submit written and oral examinations for review and approval.

PEL/OPS 30 September 2007

ii. Review qualifications of examiners prior to their appointments by the operators.


iii. Conduct follow-up inspections to ensure consistency and reliability of testing by the designated/delegated organizations or examiners for written and oral examinations.



APPENDIX 3-3-4



The GCAA has not established a system for the certification (authorization) of aviation training organizations for the training of air traffic controllers and aircraft maintenance engineers (AME). In addition, it does not ensure the qualification and competency of the delegated instructors from the training organizations, nor is any surveillance conducted of the delegated tasks.





DATE(S) GCAA shall ;

I. Coordinate with ATC Audit and Airworthiness to establish initial certification and /or approval of designated/delegated training organizations for the training of Air Traffic Controllers and Aircraft Maintenance Engineers.

PEL/ATS Inspector/Air

30 June 2008

II. Request examiners to submit their qualification records for review and approval prior to designation.


30 September 2007

III. Monitoring and supervision of delegated instructor/ examiners qualification and competency checks.


30 September 2007

IV. Request examiners to submit written and oral examinations for review and approval.


15 August 2007

V. Inspections will be conducted biennially to ensure proper surveillance of the delegated tasks and monitoring of the qualification and competency of the instructors of these training organizations.


30 June 2008


APPENDIX 3-3-5



In practice, the GCAA converts and validates foreign AME licences issued by other ICAO Contracting States. However, the requirements established in the CARs only address the issuance and validation of AME licences. In addition, the GCAA does not ensure that the requirements under which the original AME licences were issued meet the CARs or ICAO Annex 1 provisions, nor does it verify the validity of the original licences with the issuing authority. One approved maintenance organization (AMO) file reviewed contained evidence of an AME violating the conditions of his licence and letters of notification to the AME and the employing AMO. Although a response from the AME was received, and he did not apply for the renewal of his licence, no further action on the part of the GCAA was taken, and there was nothing in the AME’s file documenting the occurrence.





DATE(S) I. LI 1818, Regulation Part 5 to be amended to include

the requirements and procedures for the conversion of AME licenses. The PEL office will coordinate with Legal to issue a technical directive in support of this regulation.

PEL/Airworthiness/Legal

31 August 2007

II. Authenticity of AME licences shall be verified from the issuing Authority to ensure that the requirements under which the original licence was issued meets ICAO Annex 1 provisions.

Airworthiness

1 December 2006

III.The GCAA shall conduct random inspections to verify any evidence of an AME not performing his duties in accordance with the prescribed privileges and conditions of the license. The AMO issue will be appropriately followed up and resolved.

Airworthiness

2 January 2007

IV. Airworthiness enforcement file shall be established to document the occurrence of violations of individual AMEs.

Airworthiness

1 December 2006


APPENDIX 3-4-1

CORRECTIVE ACTION PLAN PROPOSED BY GHANA RELATED TO AIRCRAFT OPERATIONS CERTIFICATION AND SUPERVISION

AUDIT FINDING OPS/01

The GCAA has established a certification system for air operators. However, the CARs, Part 9 provides for the granting of an operating permit, which is not in compliance with Annex 6 requirements. This has allowed an applicant for an air operator certificate (AOC) to start international flights with wet leased aircraft without complying with the CARs and Annex 6 requirements. Furthermore, although the CARs only allow an operating permit to be issued for a period not exceeding six months, one operating permit was issued for a period of one year and subsequently renewed for a second one year period. In addition, no significant differences between the CARs and ICAO Annex 6 have been published in the AIP of Ghana in this regard.


The CAA agrees with the findings of the ICAO audit team



DATE(S) 1. The CAA will issue technical directives to revise

GCAR 9.1.1.6.

Technical Review

Committee

31 December 2007

2. All Operators with Operating Permits have been advised to complete certification

SRD 2 April 2007

3. CAA shall ensure that all significant differences between ICAO requirements and GCARs are published in the AIP of Ghana`.

SRD Immediately


APPENDIX 3-4-2



The GCAA does not ensure that the requirements on the contents and the structure of the air operators' operations manual are respectively complied with and maintained up to date, as provided for in ICAO Annex 6. In addition, the GCAA does not ensure that all air operators establish a route guide to be used by their flight crew and develop and submit for approval a minimum equipment list/deviation configuration list (MEL/CDL).





DATE(S) The GCAA will ensure that all parts of the air operators’ operations manual, including route guide and minimum equipment list/ configuration deviation list (MEL/CDL), are submitted for approval by all air operators. In addition the GCAA will also ensure that the requirements on the contents and the structure of the air operators’ operations manual are respectively complied with and maintained up-to-date, as provided for in ICAO Annex 6.

Flt Ops 2 April 2007


APPENDIX 3-4-3



The GCAA does not ensure that an applicant for an AOC establishes and maintains a flight safety documents system, as required by ICAO Annex 6.





DATE(S) The GCAA will ensure that an applicant for an AOC and existing holders of AOC establishes and maintain a flight safety documents system as required by ICAO Annex 6 and CAR 9.3.1.28.

Flt Ops 1 August 2007


APPENDIX 3-4-4



The GCAA does not ensure that the accident prevention programmes established by air operators contain a non-punitive flight data analysis programme, as required by ICAO Annex 6.





DATE(S) The GCAA will ensure that an applicant for an AOC and existing holders of AOC establish accident prevention programmes which contain a non-punitive flight data analysis programme, as required by ICAO Annex 6.



APPENDIX 3-4-5



The GCAA has not notified ICAO of the appropriate authority responsible for the safe transport of dangerous goods by air. In addition, the GCAA has not ensured compliance with all dangerous goods-related requirements in the certification process of air operators. The GCAA also does not conduct inspections related to dangerous goods.





DATE(S) The GCAA will: - notify ICAO of the appropriate authority responsible for the safe transport of dangerous goods by air;

Manager Airworthiness

Completed

- ensure compliance with all dangerous goods related requirements in the certification process of air operators, including the training of their staff in dangerous goods and the development of an acceptance checklist;

Flt Ops

1 August 2007

- issue OPSPECS indicating whether or not the air operator is authorized to carry dangerous goods; and

Flt Ops

1 August 2007

- Conduct inspections related to dangerous goods.

Flt Ops

Continuous


APPENDIX 3-4-6



The GCAA does not ensure that air operators establish a flight dispatcher training programme prior to the issuance of an AOC. In addition, the GCAA does not ensure that, on a recurrent basis, the knowledge, skills and qualifications of flight dispatch ground instructors are maintained, as required by ICAO Annex 6.





DATE(S) 1. (a) Coordinate with operators to submit Flight

Operations Officer / Flight Dispatch Ground Instructor Training Manuals, Programme, Plan and Policy for approval prior to the recertification or issuance of AOC.

(b) Letters will be sent to operators to comply.

PEL

PEL

31 March 2007

2. Develop Procedures for the approval of Flight Dispatch Ground Instructions

PEL 15 February 2007

3. Surveillance Program, Plan and policy will be drawn.

PEL 31 January 2007

4. Inspections shall be conducted on recurrent basis to include assessment of competency of knowledge, skills and qualifications of Flight Dispatch Ground Instructors biennially prior to designation and / or approvals.

PEL


APPENDIX 3-4-7



The GCAA does not ensure that air operators maintain up-to-date and sufficient documentation concerning flight data recorder (FDR) parameter allocation and conversion equations, nor does it ensure their availability to accident investigation authorities, as required by ICAO Annex 6.





DATE(S) The GCAA will ensure that air operators maintain up-to-date and sufficient documentation concerning flight data recorder (FDR) parameter allocation and conversion equations and also ensure their availability to accident investigation authorities, as required by ICAO Annex 6.

Flt Ops

31 August 2007


APPENDIX 3-4-8



The GCAA has established a surveillance programme of air operators; however, this programme does not take into account the monitoring of the air operators' financial conditions.





DATE(S) The GCAA will include the monitoring of air operators’ financial conditions in the surveillance program



APPENDIX 3-4-9



The GCAA does not ensure that air operators establish a policy and procedures to enable cabin crew to discreetly communicate with flight crew in the event of suspicious activity or security breach in the passenger cabin.





DATE(S) The GCAA will ensure that air operators establish a policy and procedures to enable cabin crew to discreetly communicate with flight crew in the event of suspicious activity or security breach in the passenger cabin`



APPENDIX 3-5-1

CORRECTIVE ACTION PLAN PROPOSED BY GHANA RELATED TO AIRWORTHINESS OF AIRCRAFT

AUDIT FINDING AIR/01

The GCAA has not developed procedures for the acceptance of type certificates required for the issuance of a standard or special certificate of airworthiness in accordance with the technical directives published on the Ghana Gazette on 16 November 2006.


GCAA agrees with the findings and recommendations of the ICAO audit team.



DATE(S) GCAA has developed procedures for the acceptance of Type Certificate for the issuance of a standard or special certificate of airworthiness in accordance with the Technical Directives gazetted on 16 November 2006.

AID 28 February 2007


APPENDIX 3-5-2



The GCAA has not established clear requirements and procedures for the approval of modifications and repairs, including the need for the engineering data to be approved and guidelines on what is acceptable as approved data.


GCAA agrees with the findings and recommendations of the ICAO audit team.



DATE(S) I. GCAA has established clear requirements for the approval of modification and repairs including the approval of engineering data and guidelines for accepting approved data.

AID 15 August 2007

II. CAA has embodied into the Aviation Safety Inspectors Handbook procedures for the approval of modification and repairs including the approval of engineering and guidelines for accepting approved data.



APPENDIX 3-5-3



The Ghana CARs imply that the GCAA will take some action in order for airworthiness directives (ADs) from the State of Design to apply to Ghana-registered aircraft, when in fact, the intention is for the ADs to apply directly. The CARs also provide for additional airworthiness action to be taken; however, procedures have not been developed for determining when additional action is necessary and coordinating with the State of Design.


GCAA agrees with the findings and recommendations of the ICAO audit team



DATE(S) GCAA has amended the CARs to ensure that the applicability of ADs for Ghana registered aircraft in the CARs mandate compliance with the ADs from the State of Design.

AID 15 August 2007


APPENDIX 3-5-4



The GCAA has not established a requirement for human factors principles to be observed in the design and application of maintenance programmes in conformance with ICAO Annex 6.


GCAA agrees with the finding of the ICAO audit team.



DATE(S) GCAA has included in the CARs and ASI handbook the requirement for human factors principles to be observed in the design and application of maintenance programmes in accordance with ICAO Annex 6.

AID 15 August 2007


APPENDIX 3-5-5



The procedures and forms for the issuance of export airworthiness approvals established by the GCAA do not include determining if the importing State has any special regulatory requirements and specifying the compliance status with these requirements on the approval issued.


GCAA agrees with the findings of the ICAO audit team



DATE(S) GCAA has amended the procedures and forms for the issuance of airworthiness approvals to include determining if the importing State has any special regulatory requirements and specifying the compliance status with these requirements on the approval to be issued.



APPENDIX 3-5-6



The airworthiness notices issued to date by the GCAA have not been reviewed to ensure that they reflect the current regulatory system. Furthermore, when a new airworthiness notice is issued, previous notices on the same subject are not cancelled or superseded as appropriate. In addition, the GCAA has not developed and published industry guidelines for the proper usage of parts removed from an aircraft no longer in service, including parts from aircraft involved in accidents, or for the disposal of scrapped parts.





DATE(S) GCAA has reviewed and updated the set of existing AWNs to reflect the current regulatory system. Procedures and shall also ensure previous notices are cancelled prior to the issuance of any new ones to ensure a coherent system. Industry guidance has been developed and published for the proper usage of parts removed from an aircraft no longer in service, including parts from aircraft involved in accidents, or for the disposal of scrapped parts.

AID 8 January 2007


APPENDIX 3-5-7



The procedures used by the GCAA aviation safety inspectors (airworthiness) for the review of the air operators' maintenance control manuals and maintenance programmes and AMO procedures manuals do not ensure that the documents contain all the required contents and that any deficiencies identified during the approval process are documented, retained and resolved prior to approval.





DATE(S) GCAA has developed checklists for the review of air operator maintenance control manuals, maintenance programmes and AMO procedures manuals to ensure that the documents contain all required contents and that any deficiencies identified during the approval process are documented, retained and resolved prior to approval.

AID 15 January 2007


APPENDIX 3-5-8



The GCAA has established procedures for the approval of reduced vertical separation minimum (RVSM) operations. However, contrary to the established procedures, one RVSM operational approval was issued to an aircraft prior to requesting and receiving a height-keeping monitoring report for the aircraft.





DATE(S) GCAA shall ensure procedures for RVSM operational approval are strictly adhered to.

AID 1 January 2007


APPENDIX 3-5-9



The GCAA has not established requirements and procedures for the approval of the various types of leases among commercial air transport operators, including the airworthiness aspects that should be addressed.





DATE(S) The GCAA shall establish clear requirements for the approval of the various types of leases among commercial air transport including the airworthiness aspects that should be addressed.

AID 15 August 2007

GCAA has established clear procedures for the approval of the various types of leases among commercial air transport including the airworthiness aspects that had to be addressed.

AID 15 January 2007


APPENDIX 3-5-10



In practice, the GCAA validates foreign AMOs based on, and contingent upon, the validity of the locally approved AMO certificate after the conduct of a physical inspection. However, the CARs do not provide for such an approval, and the procedures for validation do not specify that a local CAA approval is required, nor do they include an assessment of the local requirements to ensure compliance with the CARs.


GCAA agrees with the findings of the ICAO audit team.



DATE(S) GCAA shall establish requirements for the validation of foreign AMOs in accordance with its current practice to include the need for the foreign AMO to have and maintain an approval from the local CAA approval and for the assessment of the local requirements to ensure compliance with the CARs.

AID 15 August 2007

GCAA has developed procedures for the validation of foreign AMOs in accordance with its current practice to include the need for the foreign AMO to have and maintain an approval from the local CAA approval and for the assessment of the local requirement to ensure compliance with the CARs.

AID 15 January 2007


APPENDIX 3-5-11



The GCAA has established an airworthiness surveillance programme on a biannual basis that includes ramp inspections, certificate of airworthiness renewal inspections, base inspections and spot inspections. However, no system has been implemented to monitor the completion of inspections planned.





DATE(S) GCAA has established a system to provide visibility of the ongoing implementation of the airworthiness surveillance programme to ensure the continuing supervision of the operations conducted by AOC holders and AMOs.

AID 15 January 2007


APPENDIX 3-5-12



The GCAA has established requirements and forms for the reporting of faults, malfunctions and defects, and issued an airworthiness notice on the subject; however, this requirement has not been implemented for a recently approved AMO, and reports received by the GCAA have not been forwarded to the organization responsible for the type design.


GCAA agrees with findings of the ICAO audit team.



DATE(S) GCAA has distributed to all AOC holders and AMOs the requirements for reporting of faults, malfunctions and defects. GCAA shall also ensure that all reports on faults, malfunctions and defects received are forwarded to the organisation responsible for the Type Design.

AID (Quality

Assurance Group)

15 January 2007


APPENDIX 3-6-1

CORRECTIVE ACTION PLAN PROPOSED BY GHANA RELATED TO AIRCRAFT ACCIDENT AND INCIDENT INVESTIGATION

AUDIT FINDING AIG/01

The Ghana Civil Aviation Act, 2004 (Act 678) empowers the Minister to make regulations for the investigation of aircraft accidents. However, the Act has not been amended to keep abreast of amendments to ICAO Annex 13 to provide for revised procedures related to the investigation of accidents and incidents, including serious incidents, the reporting thereof and preventive actions to be instituted.





DATE(S) (i) GCAA shall amend the Ghana Civil Aviation Act, 2004

(Act 678) to reflect the current procedures relating to the investigation of accidents and incidents contained in ICAO Annex 13

SRD/AIB/Legal 15 August 2007

(ii) GCAA shall amend the CAR part 13 to reflect this change

TRC 30 June 2008

(iii) AIM procedures shall also be revised to reflect this amendment

SRD 30 June 2007


APPENDIX 3-6-2



The address and contact numbers provided by the GCAA in the Aircraft Accident Investigation Manual are not up to date. Furthermore, the AIP of Ghana, which convey the information to all stake holders worldwide, does not include the address and contact numbers to report an accident or incident.





DATE(S) (i) GCAA has forwarded the following details as

amendment to it’s contact information in the accident investigation manual ICAO Doc. 9756;

e-mail address:

[email protected] Tel: (233) 21-773283 (24 hour)

Fax: (233) 21-769401 (24 hour)

SRD/AIB 5 December 2006 23 January 2007

(ii) The AIP shall be amended to include the address and contact numbers for reporting an accident or incident.

AIS

31 December 2007

(iii) GCAA shall ensure that, contact information is made available on the accident and incident data reporting (ADREP) page of the ICAO-NET website.

SRD 30 June 2007


APPENDIX 3-6-3



The CARs, Part 13, paragraph 13.7.1 defines the powers of the investigator-in-charge of aircraft accidents; however, there is no regulation in place giving investigators the power for unhampered access to air traffic services (ATS) recordings.





DATE(S) The CARs Part 13 shall be revised to ensure that the investigator-in-charge has unhampered access to ATS recordings and documents to enable a detailed examination during an investigation.

TRC

15 August 2007


APPENDIX 3-6-4



The GCAA Aircraft Accident Investigation Manual, paragraph 4.2 defines the eligibility of participants to receive accreditation by the Accident Investigation Board during an investigation. However, the entitlements and obligations in the authorizations issued to accredited representatives and advisers are not clearly defined.





DATE(S) The Aircraft Accident Investigation Manual (AIM), paragraph 4.2 shall be revised to clearly define the entitlements and obligations of accredited representatives and advisors

SRD/AIB 30 June 2007


APPENDIX 3-6-5



The GCAA Aircraft Accident Investigation Manual, Appendix E contains an overview of a generic two-year training programme for accident investigators; however, there is a lack of a detailed training plan and prioritization of the type of training to be provided.





DATE(S) (i). The GCAA shall develop a bi-annual training plan to

reflect the type of training programme proposed

SRD/AIB

4 January 2007

(ii). The training shall commence as required in accordance with the established training plan

SRD/AIB

May 2007 — November 2009

(iii). The training plan shall be implemented in order of priority

SRD/AIB

`


APPENDIX 3-6-6



The GCAA provides accident investigators with basic equipment to enable the conduct of an accident/incident investigation. However, the investigators are not provided with protective equipment against biological and other hazards at accident sites.





DATE(S) GCAA shall include in the 2007 corporate budject for the purchase of protective equipments against biological and other hazards at accident sites.

DG

30 April 2007


APPENDIX 3-6-7



The Ghana CARs, Part 13, Chapter 13.12 requires the investigator-in-charge to submit a report to the Director-General of the GCAA, who in turn is required to forward the report to the Minister responsible for civil aviation. However, the investigator-in-charge and the investigator-in-chief report directly to the Minister, which creates a potential conflict of interest and the perception that the investigation may not be conducted impartially and independently.





DATE(S) (i) A reporting procedure shall be established in the

manual that ensures full independence of the investigation without GCAA involvement.

SRD/AIB

30 June 2007

(ii) CAA shall also amend the CARs Part 13 Chapter 13.21 to permit the Investigator-In-Charge to submit the report directly to the Minister through the Investigator-in-Chief.

SRD/AIB 15 August 2007


APPENDIX 3-6-8



The GCAA Aircraft Accident Investigation Manual, Chapter 7 describes the procedure for the processing of comments received from the States that participated in the investigation. However, the procedure does not include the process of seeking comments from the operator through the State of the Operator or from the organizations responsible for the type design and the final assembly of the aircraft through the State of Design and the State of Manufacture, respectively.





DATE(S) The GCAA Aircraft Accident Investigation Manual (AIM) shall be revised to include a procedure which ensures that a copy of the final draft report is sent to the operator, the type design organisation and the final assembly organisation through their respective states to submit their comments.

SRD/AIB

30 June 2007


APPENDIX 3-6-9



The Ghana CARs, Part 13.17 requires Ghana to forward a notification of an accident or serious incident to the interested parties. However, ICAO has not always been included in the notifications of accidents or serious incidents as required and when applicable.





DATE(S) GCAA shall ensure that ICAO is always notified of accidents or serious incidents as required and when applicable with a minimum delay. Evidence: A notification to ICAO on a recent incident of Jordan Aviation flight (registration JY-JAH) on 06/12/06 within 2 days of the occurrence.

SRD/AIB

Immediately


APPENDIX 3-6-10



The Ghana CARs, Part 13.25 defines the establishment of a voluntary incident reporting system, which shall be non-punitive and afford protection to the sources of information, and the establishment of a data base, using standardized formats to facilitate data exchange and effective analysis of the information. However, the GCAA has not yet implemented the voluntary incident reporting system, including the associated non-punitive procedures, and the data base.





DATE(S) (i) GCAA shall establish a voluntary and non-punitive

incident reporting system

SRD/AIB

31 December 2007

(ii) GCAA shall establish an accident and incident database in ICAO standardised formats to facilitate the effective analysis of information obtained.

SRD/AIB

31 December 2007


APPENDIX 3-7-1

CORRECTIVE ACTION PLAN PROPOSED BY GHANA RELATED TO AIR NAVIGATION SERVICES

AUDIT FINDING ANS/01

The CARs, Part 19 (Rules of the Air) and Part 24 (Air Traffic Services) are in conformance with ICAO Annexes 2 and 11 provisions. However, these regulations do not reflect Africa Indian Ocean (AFI) Regional Supplementary Procedures (SUPPs) contained in ICAO Doc 7030, and the Ghana AIP, GEN 1.7 contains some differences from Annex 2.





DATE(S) GCAA shall:

(i) Ensure that the requirements of ICAO Annexes 2 and 11 over the high seas airspace, for which Ghana has accepted responsibility for the provision of ATS, are applicable without exception.

ATS Inspector/

Legal

31 December 2007

(ii) Ensure that CARs are harmonized with AFI Regional SUPPS( contained in ICAO DOC. 7030)

ATS Inspector/

Legal

30 June 2008

(iii) Update Ghana AIP to reflect current compliance with ANNEX 2. .

ATS Inspector/

Legal

31 December 2007


APPENDIX 3-7-2



In accordance with regional air navigation agreements, the GCAA is responsible for the provision of air navigation services (ANS) within the Accra Flight Information Region (FIR), which includes the high seas, airspace of Benin, Equatorial Guinea (partly), Ghana, Sao Tome (partly), and Togo. This includes the provision of: ATS; aeronautical telecommunications; aeronautical information services; meteorological services for international air navigation; and aeronautical search and rescue. However, no formal coordination mechanism has been established or implemented between Ghana and the other member States of the Accra FIR to ensure that their regulations are harmonized.


The CAA agrees with the finding of the ICAO audit team; however Equatorial Guinea is not part of Accra FIR



DATE(S) GCAA shall:

I. Identify and forward findings to Accra FIR members and spearhead the need for formal coordination.

CAA/ATS 30 May 2007

II. Present a working paper on harmonization of common procedures on the Accra FIR at the impending Intra FIR meeting to address harmonization procedures.

ATS

December 2007


APPENDIX 3-7-3



Ghana has implemented ICAO airspace classification within the Accra FIR in conformance with ICAO Annex 11, including Class F airspace in the oceanic part of the FIR. The CARs, Part 19 (Rules of the Air) and the airspace classification published in the AIP of Ghana do not reflect the two-way radio communications requirement for visual flight rules (VFR) flights Class E, Class F and Class E airspace in accordance with the AFI Regional SUPPs contained in ICAO Doc 7030. Furthermore, although the Accra Oceanic FIR is situated at the Atlantic Ocean Interface between the AFI, North Atlantic and South American Regions (Area of Routing AR-2), Ghana is not involved in the regional/interregional implementation activities carried out by the established informal meetings for the improvement of ATS over the South Atlantic (SAT Group).





DATE(S) GCAA shall:

i. Monitor effectiveness of two way radio communication

ENG/ATS November 2007

ii. Re-classify the airspace with respective to radar coverage.

ATS November 2007

iii. Make budgetary provisions to ensure regular participation in regional/interregional implementation activities aiming at improving the provision of air navigation services over the high seas air space

ATS November 2007


APPENDIX 3-7-4



The GCAA has embarked in 2004 and 2005 on a programme of upgrading and expansion of aeronautical communications networks within the Accra FIR using satellite technology (very small aperture terminals [VSAT]), including fixed communications with neighbouring States/FIRs and extended very high frequency (VHF) radio coverage within the FIR. However, a number of VSAT links have not yet been improved or implemented in order to fully meet ICAO Annex 11 requirements for fixed communications between the Accra FIR and adjacent States/FIR. Furthermore, air-ground communication requirements are not clearly established with respect to the provision of flight information services to flights operated under VFR.





DATE(S) GCAA shall ensure that ICAO Annex 11 requirements for fixed communications between Accra FIR and adjacent states/FIR are implemented in an efficient manner, in coordination with adjacent states/FIR – and that air-ground communication requirements with respect to provision of flight information service to flights under VFR are clearly established.

ENG/ATS

31 December 2008


APPENDIX 3-7-5



The CARs, Part 24 establishes a requirement for the implementation of ATS safety management programmes. However, although the GCAA has already developed guidelines to implement such programmes, systematic and appropriate safety management programmes have not yet been implemented by the GCAA in conformance with the provisions contained in ICAO Annex 11, Chapter 2.





DATE(S) The GCAA shall:

i Appoint a Safety/Quality Assurance Manager (ATS) to implement the already developed guidelines for a systematic and appropriate Safety Management System.

ATS

February 2007

ii Establish a Safety Committee to assist in the implementation and Monitoring of the Safety Management Programme

ATS June 2007

iii Organise a Safety Awareness Seminar/Workshop

ATS October 2007

iv Establish a Training Programme to train other personnel in this area

ATS December 2007

v continue to review and amend the ATS Safety Management System by the GAP Analyses Programme when necessary.

ATS Continuous


APPENDIX 3-7-6



The GCAA has not established regulations and procedures applicable to visual and instrument flight procedures (Procedures for Air Navigation Services-Aircraft Operations [PANS-OPS]). There is not a formal agreement with the contracting agency (Jeppesen) clearly establishing GCAA requirements and oversight functions, and the procedures developed by the PANS-OPS service provider are not subject to GCAA approval prior to their publication. Furthermore, the GCAA does not retain all procedure design documentation so as to allow any data anomalies or errors found during the production, maintenance or operational use of the procedure to be corrected. In addition, some applicable procedures have not yet been developed and published for instrument runways in accordance with the provisions contained in ICAO Doc 7474 (AFI Air Navigation Plan).





DATE(S) The GCAA shall :

i. Establish and promulgate PANS-OPS regulations and procedures to be applicable in Ghana and ensure that they are compliant with ICAO PANS – OPS (Doc 8168)

CAA/ATS December 2008

ii. Establish PANS- OPS approval procedures, and

CAA December 2008

iii. Ensure that all procedures design documentation is retained so as to allow any data anomalies or errors found during the production, maintenance or operational use of the procedures, to be corrected; and

AIS/CAA

December 2008

iv. Develop and publish procedures, for instrument runways in accordance with the provisions contained in ICAO Doc. 747 (AFI Air Navigation Plan)

ATS/AIS December 2008


APPENDIX 3-7-7



The GCAA has contracted the production of aeronautical charts to a private agency. However, a cartography service has not been established to address matters pertaining to ICAO Annex 4 provisions, including safety oversight functions. In addition, there is no formal coordination between the GCAA and the Ghana Surveys Department to ensure that the charts and relief data used for the development of aeronautical charts and PANS-OPS procedures are reliable and accurate.





DATE(S) (i) GCAA shall contract the services of a cartographic expert or agency to oversee the quality, reliability and accuracy of charts and relief data produced by Ghana Survey Department for aeronautical and PANS-OPS procedures

CAA /AIS 30 June 2008


APPENDIX 3-7-8



Ghana has established a rescue and coordination centre (RCC) and rescue and coordination sub-centres (RSCs) within the Accra search and rescue region (SRR). However, it has not established a joint RCC to coordinate aeronautical and maritime search and rescue (SAR) operations. Furthermore, cooperation agreements have been signed with Burkina Faso and Togo; however, additional cooperation agreements with neighbouring States have not yet been concluded. In addition, the GCAA has not established SAR training requirements to ensure availability of sufficient work force skilled in coordination and operational functions.





DATE(S) The GCAA ensure :

i. That a joint RCC is established to coordinate aeronautical and maritime Search and Rescue (SAR) operations:

SAR/MRCC December 2008

ii. Cooperation agreements with Benin and Cote D’Ivoire are concluded

CAA/SAR December 2007

iii. SAR training requirements are met such that sufficient workforce, skilled in coordination and operational functions, are available.

CAA/SAR November 2007


APPENDIX 3-7-9



The GCAA, through its Directorate of Safety Regulations, is in the process of establishing and implementing a safety oversight system for ensuring the effective implementation of safety-related procedures in the fields of ANS. However, only ATS and aeronautical telecommunications are currently covered. Related inspections are conducted by one ATS and one engineering inspector who use dedicated audit handbooks and take follow-up action on the inspection reports, as required in order to solve identified deficiencies. However, while the training programme developed by the GCAA to support the ANS safety oversight implementation process has not yet been implemented and completed, the Director-General of the GCAA has already accredited some ANS technical staff as inspectors. Furthermore, the trends in the industry are not monitored to accommodate new requirements when necessary.





DATE(S) The GCAA shall ensure that :

(i) Establish and implement a safety oversight system for ensuring effective implementation of safety-related procedures in all functional air navigation areas.

CAA 30 June 2008

(ii) Ensure that the qualification process, including training requirements for ANS inspectors, is clearly defined and that the established requirements are implemented prior to the assignment of safety oversight functions to the ANS inspectorate staff.

CAA 30 June 2008

(iii) Monitor the trends in the industry to accommodate new requirements i.e staffing, training and working environment

CAA 30 June 2008


APPENDIX 3-7-10



The AIP of Ghana is published in three parts, in conformance with ICAO Annex 15, Chapter 4 and Appendix 1, which are included in a single volume. However, the AIP contains discrepancies with respect to applicable air navigation regulations, procedures and practices, as well as differences from ICAO SARPs.





DATE(S) The GCAA to ensure that:

i. Ghana CARs are reflected in the AIP of Ghana without discrepancies.

TRC/AIS December 2007

ii. The AIP of Ghana is kept current and the safety critical information published therein is accurate and updated in an efficient and timely manner.

TRC/AIS Continuous


APPENDIX 3-7-11



The GCAA has not developed updated ATS contingency plans applicable in the event of disruption or potential disruption of ATS or related supporting services.





DATE(S) The GCAA to :

ATS contingency plans that were developed for Y2K are revised and kept up-to-date including general disruptions or potential disruptions of ATS or related supporting services

ATS

30 September 2007


APPENDIX 3-7-12



The Ghana Meteorology Agency (GMA) offices do not issue wind shear warnings for aerodromes such as Accra Kotoka International Airport, where wind shear is considered as a safety factor, in conformance with ICAO Annex 3, Part I.





DATE(S) The GCAA to shall ensure that : All agreements with the Ghana Meteorological Agency shall ensure compliance with Annex 3, Part 1.

ATS/Legal

30 September 2008


APPENDIX 3-7-13



The GCAA has implemented one area navigation (RNAV)/required navigation performance (RNP) 10 route (UM 114) following a satisfactory pre-implementation safety assessment, in coordination with all the States involved in the implementation. In addition, the GCAA has developed a National Safety Plan within the framework of AFI reduced vertical separation minimum (RVSM) programme and submitted it to the AFI Regional Monitoring Agency (ARMA), which is tasked with the performance of related pre-implementation and post-implementation safety assessments. However, there are no formal arrangements between the GCAA and the ARMA with respect to the provision of periodic safety assessments for RNP and RVSM operations.





DATE(S) Discussions have been initiated between GCAA and ARMA for the establishment of a formal arrangement for the provision of periodic safety assessments.

ATS/Legal 30 September 2008


APPENDIX 3-7-14



The GCAA has established a formal mechanism for the review and elimination of deficiencies identified within the framework of the AFI Planning and Implementation Regional Group (APIRG); however, there is no adequate coordination with Ghana adjacent States/FIRs to ensure the resolution of some critical deficiencies (i.e. aeronautical fixed telecommunications).





DATE(S) The GCAA to expedite the resolution of ANS deficiencies identified with the framework of the AFI planning and implementation Regional Group (APIRG) or reported by other relevant sources of information in coordination with its adjacent States / FIRs. Budgetary allocations will be made for coordination visits to adjacent States / FIRs to ensure elimination of deficiencies identified in the framework

EID/ATS

December 2008


APPENDIX 3-7-15



According to the terms of reference for AIS technical staff defined in the Aeronautical Information Services Procedures Handbook, the AIS Section of the GCAA is tasked with the following functions: ATS reporting; telecommunication operations; statistics and billing/collecting; and processing of operators' over flight and landing requests. However, the tasks and responsibilities for each ANS functional area have not been clearly established, and written terms of reference for the technical staff involved at the service provider's level have not been developed.





DATE(S) The GCAA shall ensure that: Tasks and responsibilities for the functional areas are clearly defined and documented in the respective Procedures Handbooks as well as GCAA Human Resources Manual Qualification and experience requirements are developed for specific functions

ATS/HR

December 2007


APPENDIX 3-7-16



The organizational structure of the GCAA Air Traffic Services Department establishes the lines of accountability and responsibility with respect to ATS, AIS and SAR. However, AIS and SAR are shown as part of ATS, and there is no clear indication as to the offices responsible for aeronautical charts (MAP), PANS-OPS and coordination of MET-related matters.





DATE(S) The GCAA shall amend its organizational structure to clearly establish lines of responsibility.

CAA December 2007


APPENDIX 3-8-1

CORRECTIVE ACTION PLAN PROPOSED BY GHANA RELATED TO AERODROMES

AUDIT FINDING AGA/01

The GCAA has established a legislative and regulatory framework for the certification of its aerodromes. However, to date, only one of its designated aerodromes, the Kotoka International Airport in Accra has been certified. Furthermore, the requirement for aerodromes to establish a formal safety management system (SMS) has only been partially implemented. In addition, the aerodrome manual approved for the Kotoka International Airport does not include detailed operating procedures and particulars of the facilities, equipment, personnel and procedures for meeting the requirements for aerodrome services to be provided, such as RFF, bird hazard reduction and removal of disabled aircraft. Although a formal mechanism exists by which regulatory staff should evaluate the competence and experience of aerodrome staff, the associated procedures and guidance material have not yet been developed and made available to the industry. The certified status of an aerodrome is not currently published in the AIP of Ghana.


GCAA agrees with the findings and recommendations of the ICAO audit team, but would like to amend the current regulations on the requirements for the certification of aerodromes to affect only aerodromes used for international operations



DATE(S) • Amendment to require only aerodromes used for

international operations to be certified has been drafted and being reviewed by Technical review Committee.

• Legal to forward it for final gazetting

Aerodromes Safety &

Standards/ Tech.

Review Committee

Legal Dept.

16 August 2007

15 October 2007

It will be ensured that the requirements for the Safety Management System are fully implemented by all certified aerodromes

Aerodromes Safety & Standards

22 September 2007


APPENDIX 3-8-1 (CONT.)




DATE(S) • Current procedures shall be reviewed. • Enhanced procedures and guidance materials including

Competence and experience Assessment Manual for both regulatory and industry shall be developed.

• The KIA Manual shall be reviewed to comply with all the requirements of the GCAR Part 14.


31 December 2007

• Submission of certification documents to AIS • The publication of KIA certified status in the AIP

Aerodromes Safety &

Stds.

AIS

Completed

31 December 2007


APPENDIX 3-8-2



The GCAA has developed and promulgated the CARs, Part 14 for the regulation and certification of its designated aerodromes in order to implement the provisions of ICAO Annex 14, Volume I. However, the GCAA has not established a clear policy as regards ICAO Recommended Practices, some of which have been upgraded to a national standard but are in conflict with ICAO less restrictive Standards. In addition, although there are no civil heliports in Ghana, the GCAA has developed the CARs, Part 14, Volume 2 containing provisions for the design and operation of heliports. However, it has not yet been approved by the Parliament and come into force





DATE(S) i) The GCAR Part 14 is being reviewed to address all conflicting requirements prior to submission to Legal for approval and necessary action.

Aerodromes Safety &

Standards/ Tech.

Review Committee

16 October 2007

ii) Legal to forward Section 2, Part 14 of the GCARs for final promulgation.

Legal Dept.

30 June 2008


APPENDIX 3-8-3



The GCAA Aerodrome Safety and Standards (ASAS) Section is tasked with aerodrome certification and surveillance activities. However, this section relies on personnel and inputs from other sections within the Safety Regulations Department. The functions and responsibilities of the ASAS are not clearly defined, and the post of Deputy Director heading the section has not been filled. Currently, there is a lack of direction and coordination of the safety oversight activities. Furthermore, the three technical officers of the ASAS are from a limited range of professional backgrounds. Although some technical expertise is available from other GCAA areas to assist in the ongoing aerodrome certification process, the effectiveness of the safety oversight function is hampered by the lack of staff with wider professional backgrounds, such as aerodrome operations. In addition, the certification process is still in its early stages, and in view of the demanding nature of continuing effective safety oversight activities and the need for enhanced training to cover all the disciplines involved in the certification process, the current staffing level is unlikely to meet the requirements.





DATE(S) The current organizational structure has been reviewed. The Aerodrome Safety and Standards Section now has sufficient technical staff of the necessary disciplines, competence and experience to form a cohesive team, to enable the authority to implement its aerodrome certification programme and carry out its safety oversight function effectively.

Human Resource

Dept.

Completed


APPENDIX 3-8-4



The GCAA has established a training policy and programme for its aerodrome regulatory staff; however, the scope of the training requirements does not include specialized areas, such as human factors, aeronautical studies and risk assessment. In addition, there is no provision for minimum initial mandatory training, including on-the-job-trainig (OJT), to become a qualified and accredited aerodrome inspector, nor are there requirements to access different levels of the inspection functions.


The GCAA acknowledges that it does not have training in specialized areas such as risk assessment and human factors in emergency planning. However, inspectors have been trained to conduct aeronautical studies and that its training requirements include minimum initial mandatory training



DATE(S) Inspectors will be trained in the area of Risk Assessment and Human Factor Principles in Emergency Planning

Director Human

Resource/ Director Safety

Regulation

July 2008


APPENDIX 3-8-5



The GCAA has developed a number of documents as guidance material for its technical staff and to assist the industry in meeting its national requirements. However, this material does not cover all disciplines involved in the certification process of aerodromes, and its scope does not include certain areas, such as aeronautical studies, risk assessment and bird strike hazard, among others.





DATE(S) Additional guidance material will be developed to provide more guidance to technical staff to assist the industry in meeting requirements.


30 March 2008


APPENDIX 3-8-6



The safety oversight function includes the review and approval of exemptions where non-conformance to established requirements is deemed necessary and approved by the regulatory authority. Such exemptions are normally based on aeronautical studies and/or risk assessments. However, the GCAA has not issued a formal policy stating the circumstances and rationale under which aeronautical studies and/or risk assessments may be used. In addition, limited guidance has been made available to aerodrome operators and regulatory staff on risk assessment principles and processes, and ASAS staff has not received formal training in the development, evaluation and application of aeronautical studies and/or risk assessments. Furthermore, there is no clear process by which non compliances of operational significance are processed and notified to air operators and other interested parties.





DATE(S) A policy to define the circumstances under which an aeronautical study and/or risk assessment may be used to support the application of a non-conformance or non-adherence to published requirements.


30 March 2008

The GCAA shall develop comprehensive guidance on the development, evaluation and use of aeronautical studies and risk assessments


APPENDIX 3-8-7



The GCAA has not established a requirement for the implementation of a quality system in order to ensure the accuracy, integrity and protection of aeronautical data reported by the aerodrome operator throughout the data transfer process.





DATE(S) The GCAA shall implement a quality system to ensure the accuracy, integrity and protection of aeronautical data throughout the data transfer process.

AIS/Aerodromes Safety & Standards

30 April 2008


APPENDIX 3-8-8



The GCAA has not established criteria and associated industry guidelines to regulate the use of a pavement by an aircraft with an aircraft classification number (ACN) higher than the reported pavement classification number (PCN). In addition the published pavement bearing strengths are not current and do not reflect the real status of the runway pavements.





DATE(S) The GCAA shall establish criteria and associated industry guidelines to regulate the use of a pavement by an aircraft with an aircraft classification number (ACN) higher than the reported pavement classification number (PCN).


31 December 2007

Published pavement strength is being re-evaluated by a group of experts.

Projects 31 May 2007


APPENDIX 3-8-9



The GCAA does not ensure that all aerodrome operators monitor and report the condition of the movement areas and related facilities and comply with national requirements for the measurement and reporting of runway friction characteristics, in particular, to determine friction levels for maintenance planning purposes; to assess when a runway may become slippery when wet or under unusual conditions; and to report the type of friction measuring device used.





DATE(S) The GCAA shall ensure that all aerodrome operators comply with the national requirements for the measurement and reporting of runway friction characteristics, including the type of friction measuring device used.


28 May 2008


APPENDIX 3-8-10



The GCAA does not ensure the provision of runway end safety areas (RESAs) at all aerodromes in compliance with national requirements and has no formal mechanism to ensure that the runway surroundings are safe for use by aircraft in the event of an aircraft overrunning or undershooting the runway. In addition, the CARs, Part 14 contains two different and conflicting requirements for the RESA, reflecting both the ICAO Standard and Recommended Practice.





DATE(S) The GCAA shall ensure that the requirements for the provision of runway end safety areas (RESA) at aerodromes are complied with and where this requirement is not implemented, a formal risk assessment is conducted and appropriate mitigating measures applied


31 July 2008


APPENDIX 3-8-11



The GCAA does not ensure that aerodromes have monitoring systems to ensure lighting system reliability and indicate any fault which may affect control functions.





DATE(S) The GCAA shall ensure that aerodromes have monitoring systems to ensure lighting system reliability and indicate any fault which may affect control functions.


29 June 2008


APPENDIX 3-8-12



The GCAA does not ensure that an aerodrome operator’s plan for lighting, signs and markings is integrated as a whole into the aerodrome’s runway incursion and collision avoidance strategy, taking account of different aerodrome traffic intensities and visibility conditions.





DATE(S) The GCAA shall ensure that an aerodrome operator’s plan for lighting, signs and markings is integrated as a whole into the aerodrome’s runway incursion and collision avoidance strategy, taking account of different aerodrome traffic intensities and visibility conditions.


28 May 2008


APPENDIX 3-8-13



The GCAA does not require aerodrome operators to ensure that organizations performing activities at the aerodrome comply with the safety requirements laid down by the aerodrome operator.





DATE(S) The requirement of the organizations performing activities at the aerodrome to comply with the safety requirements laid down by the aerodrome operator has been drafted.

Aerodromes Safety &

Standards / Tech

Review Committee

16 August 2008

Promulgation and incorporated in the national regulation

Legal Department

31 January 2007


APPENDIX 3-8-14



The GCAA has established an inspection programme for the continued surveillance of aerodromes that is being implemented, although all designated aerodromes have not yet been certified. However, the procedures for dealing with the deficiencies identified during aerodrome inspections until their resolution are not clearly defined. In addition, the enforcement actions in the event of non-conformance with the certification requirements or an unresolved safety concern include the revocation or cancellation of the certificate; however, it does not include the imposition of operating restrictions.





DATE(S) Procedures for dealing with identified aerodrome deficiencies until their resolution shall be established. This shall include the imposition of operating restrictions in the set of enforcement actions prior to cancellation or revocation of the certificate.


30 May 2008


APPENDIX 3-8-15



The GCAA has an aircraft removal kit and related operating procedures have been developed for RFF personnel. However, it does not ensure that all designated aerodromes have formal plans for the removal of disabled aircraft, including arrangements for coordinators to be designated, the rapid availability and deployment of salvage and removal equipment between aerodromes, and the protection of evidence, custody and the removal of aircraft in conformance with ICAO Annex 13. In addition, the GCAA has not published information concerning aerodromes' capability to remove disabled aircraft.





DATE(S) It shall be ensured that all designated aerodromes have formal plans for the removal of disabled aircraft, including arrangements for coordinators to be designated, the rapid availability and deployment of salvage and removal equipment between aerodromes, and the protection of evidence, custody and the removal of aircraft in accordance with Annex 13, and publish their aircraft removal capability.


Completed


APPENDIX 3-8-16



The GCAA does not ensure that aerodrome operators restrict the operation of personnel and vehicles during low visibility operations.





DATE(S) It shall be ensured that aerodrome operators restrict the operation of personnel and vehicles during low visibility operations


30 October 2007

— END —


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