1. Airworthiness certification system
- The airworthiness certification system should be restructured along the following lines to tap private sector abilities and make full use of airworthiness certification issued overseas.
(a) Appointing aircraft manufacturers for inspection of aircraft manufactured in Japan
With respect to aircraft which have obtained type certificates, a manufacturer with sufficient manufacturing and inspection know-how should manufacture and inspect the aircraft of the particular type and when the aircraft is found to conform with the standards required for airworthiness certificate, such aircraft should be exempt from direct inspection by the government.
(b) Further use of foreign certification in the inspection of imported aircraft
Direct inspection in Japan should be waived for imported aircraft, which have obtained type certification in Japan and have also obtained airworthiness certificate in countries which have airworthiness standards on par with or higher than that of Japan
(c) Appointing aircraft maintenance contractors for inspections for extending airworthiness certificates
For the purpose of extension of airworthiness certificate, a maintenance contractor with sufficient capability in the maintenance and inspection should be allowed to carry out maintenance and inspection and if the aircraft is found to meet the mandated standards, direct government inspection should vaiwed for such an aircraft.
- With respect to annual inspections for extension of airworthiness certificates, the number of cases in which aircraft fail to pass such inspections is not necessarily low. Moreover, since foreign countries also mandate annual inspections with respect to maintenance of airworthiness, the current validity period is considered to be adequate.
2. Type Certificate system
In recent years there have been growing number of cases in which a person other than the one to whom the original type certificate was issued carries out identical changes in a multiple number of aircraft carrying the same type certificate. In such cases approval should not be required for individual aircraft but a blanket approval should be issued for the type certificate itself. This will mean that a person other than the one to whom the model certificate was originally issued will be able to obtain approval for design changes in the aircraft with the same type certificate. Such aircraft shall be deemed to have obtained a type certificate from the standpoint of airworthiness inspection. In other words STC (Supplemental Type Certification) system should be introduced.
Adoption of the proposed system, will enable imported aircraft of the type which have obtained type certificate in Japan and have also undergone design changes in accordance with the supplemental type certificate approved in Japan to be vaiwed from airworthiness inspection on the basis of airworthiness certificates issued overseas. Adoption of the STC system is likely to assure smooth functioning of the new system described above.
3. Spare parts certification system
- Tapping private sector know-how and the use of foreign certification is recommended for aircraft parts certification system. In addition to the aircraft parts produced in approved manufacturing and repair facilities, spare parts should be qualified for certification in the following cases.
(a) a part manufactured and inspected by a manufacturer with sufficient ability to manufacture and inspect such parts and found to conform with the required safety standards
(b) aircraft parts for aircraft with type certification, manufactured and inspected by a manufacturer with sufficient ability to manufacture and inspect such parts, and found to conform with safety standards
(c) aircraft parts carrying safety certificates issued overseas in countries which have safety standards on par with or higher than the Japanese safety standards
(d) aircraft parts carrying safety certificates issued by approved agent in countries with aircraft parts repair and reform systems on par with or better than that of Japan
- Under the present system, the validity of certificates for aircraft spare parts is limited. Moreover, the type of aircraft on which such a specific spare part may be installed is also specified. But, recent progress in electronics technologies has led to considerable improvement in the quality of aircraft parts. Moreover, with the diversification of aircraft specifications, parts for individual aircraft differ even if the aircraft are of the same type. Under the circumstances, government unilaterally setting validity periods or limiting the aircraft on which an aircraft part may be installed does not necessarily conform with international trends.
At the same time, the Civil Aviation law mandates that at the time of installing a spare part on an aircraft, a certified aircraft mechanic check the spare part from the standpoint of safety and this should include a check on storage condition of the spare part, as well as a confirmation of suitability of the part, by reference to the parts table for the aircraft. Under the circumstances, no problems are envisioned from the standpoint of assuring aircraft safety even in the absence of specification of validity period and spelling out of limitations on the type of aircraft on which the said aircraft part can be fitted.
In view of the circumstances, the rule mandating the specification of validity period and limiting the type of aircraft on which a part may be fitted should be reviewed.
4. Systems relating to environmental regulation
- With respect to noise pollution from propeller aircraft and helicopters and emission control from motors, Japan needs to introduce environmental protection standards based on those drawn up by ICAO. Simultaneously, a system of airworthiness certification from the environmental standpoint should be introduced. Additionally, private sector know-how and certification issued in foreign countries should be employed in order to assure conformity with environmental protection requirements.
5. Simplification and rationalization of other regulations
- With respect to certifications, the inspections for which are closely related, that is when the objectives and inspection procedures of differing regulations are similar, attempts should be made to lower the burden on the operator. For instance, noise pollution certification could be merged with the airworthiness inspection system, and the approved aircraft repair and reform facilities system and the approved aircraft fittings repair and reform facilities system could be merged. Thus simplification and rationalization of regulation should be achieved.
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