CONSULTATIVE COMMITTEE WORKSHOP 19th MAY 2016 AIRWORTHINESS CAR - PowerPoint PPT Presentation

Work in Progress – Life of Pressure Vessels ☼ Initiated by Clifford Ralston De Vaz of Etihad ☼ Issue is the ambiguity about the permissible life limits of the pressure vessels. The life limit on ground is different as compared to when the vessel is installed on aircraft ☼ The GCAA to standardize the interpretation of the requirements by the AWIs ☼ Long and constructive discussion sessions between the members of the working group, GCAA SME and Emirates SME ☼ The WG is looking at possible resolutions 22

Work in Progress – Repair of Galley Carts ☼ Initiated by Clifford Ralston De Vaz of Etihad ☼ Issue is the use of commercial parts during repair of galley carts and releasing the carts thus repaired with the document “Certificate of Conformity”. Should it be Form 1 or equivalent or is C of C an acceptable document? GCAA to provide guidance on what paperwork should an operator ask for ☼ The quest for solution is in its infancy, being researched upon. 23

Work in Progress – Use of Commercial Parts ☼ Initiated by Youssef Bahsoun of Emirates ☼ Issue is the use of commercially available parts on assemblies eventually used on aircraft and associated release documents ☼ Similar to the issue of galley carts but has wider range of parts to cover ☼ The WG is looking at possible resolutions 24

Work in Progress – FAA PMA Parts ☼ A topic of interest for many participants ☼ The GCAA to provide guidance on FAA PMA parts, including what types of FAA PMA parts are permitted for installation and the associated documentation requirements ☼ The topic has been discussed at length in all meetings ☼ Mr. Pieter Ruitenberg – Who has represented EASA on FAA PMA topic, also provided his point of view as a guest speaker during last (3 rd ) meeting ☼ EASA accepts certain categories of FAA PMA parts under EASA – FAA bilateral & TIP agreements 25

Work in Progress – FAA PMA Parts (continued) ☼ To date, the WG has been able to develop the following position:  FAA PMA Parts included in IPC by the TC Holder – are acceptable  FAA PMA Parts supplied by the STC Holder approved by the GCAA – are acceptable  FAA PMA Parts – for FAA / EASA TC aircraft – under further consideration by WG study  Availability of GCAA legal framework – under further study 26

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Organization Risk Scope ORS

xxxxxx xxxxxx xxxxxx Organisation Risk Scope - ORS Agenda • Introduction • Objective • Method • Risk Calculation • Implementation of ORS • Interfacing

xxxxxx xxxxxx xxxxxx Organisation Risk Scope - ORS Introduction Risk Based Oversight:- Risk-based Oversight (RBO) is a way of performing oversight, where planning is driven by the risk profile and execution, besides ensuring compliance, focuses on the management of operational risks.

xxxxxx xxxxxx xxxxxx Organisation Risk Scope - ORS Introduction Organization Risk Profiling Risk Based Oversight Organization Risk Scope

xxxxxx xxxxxx Organisation Risk Scope - ORS xxxxxx Introduction Organization Organization Risk Risk Scope Profiling • • Review & Update ALL Org. Aggregate all data from all sources Profile • Calculate the RI for Each Scope • Classify ALL Org. and item determine audit frequency • Analyze the RI and • Execute audit as per frequency

xxxxxx xxxxxx xxxxxx Organisation Risk Scope - ORS Organization Risk Scope ORS is a tool to identify risk in the aviation industry through data evaluation and apply a focused approach to eliminate / control risks.

xxxxxx xxxxxx xxxxxx Organization Risk Scope Program- ORS Objective: • Support State Safety Program. • Identify the weak compliance area in the UAE Aviation Industry, using audit finding data. • Strengthen the Safety and Airworthiness Standards through enhanced monitoring. • Contribute to measure effectiveness of the SMS.

xxxxxx xxxxxx xxxxxx Organisation Risk Scope - ORS Methodology • Define a model of ORS that will identify – specific risky areas of an Organization – Systemic issues for an Organization – Systemic issues in the UAE total aviation Industry • Draw a threshold level for each organization to classify the risk level. • Strengthen monitoring of the identified high risk area

xxxxxx xxxxxx xxxxxx Organisation Risk Scope - ORS Multiplication Factor V2 V1 Findings V3 RI

xxxxxx xxxxxx xxxxxx Organization Risk Scope Program- ORS Risk Severity Risk Severity factoring: • To moderate effect of different level of finding on risk calculation, each finding is biased by a multiplication factor (MF) based on finding level. • MF for Level 1 finding = X • MF for Level 2 finding =Y • MF for Level 3 finding = Z

xxxxxx xxxxxx xxxxxx Organization Risk Scope Program- ORS Method 𝑶𝒗𝒏𝒄𝒇𝒔 𝒑𝒈 𝒈𝒃𝒅𝒖𝒑𝒔𝒇𝒆 𝒈𝒋𝒐𝒆𝒋𝒐𝒉𝒕 𝒋𝒐 𝑩𝒔𝒇𝒃 𝑭𝒉. 𝑫𝑩𝑺 𝟐𝟓𝟔.𝟒𝟏 𝒈𝒑𝒔 𝑷𝒔𝒉𝒐𝒋𝒕𝒃𝒖𝒋𝒑𝒐 Specific V1= 𝑯𝒔𝒃𝒐𝒆 𝑼𝒑𝒖𝒃𝒎 𝒑𝒈 𝒈𝒃𝒅𝒖𝒑𝒔𝒇𝒆 𝒈𝒋𝒐𝒆𝒋𝒐𝒉𝒕 𝒋𝒐 𝑩𝒔𝒇𝒃 𝒈𝒑𝒔 𝒃𝒎𝒎 𝒑𝒔𝒉𝒃𝒐𝒋𝒕𝒃𝒖𝒋𝒑𝒐𝒕 V2= 𝐎𝐯𝐧𝐜𝐟𝐬 𝐩𝐠 𝒈𝒃𝒅𝒖𝒑𝒔𝒇𝒆 𝐠𝐣𝐨𝐞𝐣𝐨𝐡𝐭 𝐣𝐨 𝐁𝐬𝐟𝐛 𝑭𝒉.𝑫𝑩𝑺 𝑩𝟐𝟓𝟔𝟏.𝟒𝟏 𝐠𝐩𝐬 𝒃𝒎𝒎 𝐏𝐬𝐡𝐨𝐣𝐭𝐛𝐮𝐣𝐩𝐨𝐭 lobal 𝑯𝒔𝒃𝒐𝒆 𝑼𝒑𝒖𝒃𝒎 𝒑𝒈 𝒃𝒎𝒎 𝒈𝒃𝒅𝒖𝒑𝒔𝒇𝒆 𝒈𝒋𝒐𝒆𝒋𝒐𝒉𝒕 𝒋𝒐 𝒃𝒎𝒎 𝑩𝒔𝒇𝒃 𝒃𝒎𝒎 𝒑𝒔𝒉𝒃𝒐𝒋𝒕𝒃𝒖𝒋𝒑𝒐𝒕 𝑶𝒗𝒏𝒄𝒇𝒔 𝒑𝒈 𝑷𝒔𝒉𝒐𝒋𝒕𝒃𝒖𝒋𝒑𝒐𝒕 𝒊𝒃𝒘𝒋𝒐𝒉 𝒃 𝒈𝒋𝒐𝒆𝒋𝒐𝒉 𝒋𝒐 𝒖𝒊𝒇 𝑩𝒔𝒇𝒃 𝑭𝒉.𝑫𝑩𝑺 𝑩𝟐𝟓𝟔𝟏.𝟒𝟏 Global V3 = 𝑶𝒗𝒏𝒄𝒇𝒔 𝒑𝒈 𝒃𝒎𝒎 𝒑𝒔𝒉𝒃𝒐𝒋𝒕𝒃𝒖𝒋𝒑𝒐𝒕 V? = takes the value of 1/ 0 depending on the % calculated is above or below the defined threshold

xxxxxx xxxxxx xxxxxx Organization Risk Scope Program- ORS Risk Calculation • RISK INDEX (RI) RI = 𝑊 1x4 + 𝑊 2x2 + 𝑊 3x1 • This method ensure that “Specific” and “Global” variable do not contribute to the same level by an weightage for risk calculation

xxxxxx xxxxxx xxxxxx Organization Risk Scope Program- ORS Risk Calculation RI Description V1=0, Area which is not specific to the Org.; V2=0, Area which consumed less than 8% of the GCAA's manpower; 0 V3=0, Area which is affecting less than 15% of ALL Org. V1=0, Area which is not specific to the Org.; V2=0, Area which consumed less than 8% of the GCAA's manpower; 1 V3=1, Area which is affecting more than 15% of ALL Org. V1=0, Area which is not specific to the Org.; V2=1, Area which consumed more than 8% of the GCAA's manpower; 2 V3=0, Area which is affecting less than 15% of ALL Org. V1=0, Area which is not specific to the Org.; V2=1, Area which consumed more than 8% of the GCAA's manpower; 3 V3=1, Area which is affecting more than 15% of ALL Org. V1=1, Area which is specific to the Org.; V2=0, Area which consumed less than 8% of the GCAA's manpower; 4 V3=0, Area which is affecting less than 15% of ALL Org. V1=1, Area which is specific to the Org.; V2=0, Area which consumed less than 8% of the GCAA's manpower; 5 V3=1, Area which is affecting more than 15% of ALL Org. V1=1, Area which is specific to the Org.; V2=1, Area which consumed more than 8% of the GCAA's manpower; 6 V3=0, Area which is affecting less than 15% of ALL Org. V1=1, Area which is specific to the Org.; V2=1, Area which consumed more than 8% of the GCAA's manpower; 7 V3=1, Area which is affecting more than 15% of ALL Org.

xxxxxx xxxxxx xxxxxx Organization Risk Scope Program- ORS • ORS(2016Rev1).xlsm

xxxxxx xxxxxx xxxxxx Organization Risk Scope Program- ORS Implementation • Map risk index of Org . using Q-Pulse audit data. • Define the threshold and identified high risk area in each organization. • Strengthen monitoring of high risk area through emphasize during regular audit, to capture effectiveness of corrective action.

xxxxxx xxxxxx xxxxxx Organization Risk Scope Program- ORS Long-term Immediate Inspector Internal Enhanced audit Training to based on RI actions enhance standardization Organization Regulations with identified Risk Area Airline proactive Safety promotion External action events actions

xxxxxx xxxxxx xxxxxx Organization Risk Scope Program- ORS Follow up Action  The conventional compliance audit will continue as per the ORP audit program.  However, when high risk area identified (RI ≥ ?): – PI to share the identified risk concerns with the operator/Organization in order to initiate appropriate actions – PI to ensure follow-up on actions taken the operator/Organization. – For the next GCAA audit, PI to schedule at least 1 day addition to focus on the risk area and state in Q Pulse that the concerned areas have been covered in detail.

xxxxxx xxxxxx xxxxxx Organization Risk Scope Program- ORS Can this ORS methodology be fed with other source of data than audit data? Yes by: • ROSI • VORSY • Internal audits • External audits • Creating an new audit scope item and then classifying and categorizing each similar event accordingly (e.g. Fatigue issue may be categorized under a new audit scope item)

Xxxxxx xxxxxx xxxxxx Thank You

Hazard ID, SPI & SPT ANDREW LAWSON – May 2016

EASA Significant 7  1. Loss of Control  2. Runway Excursion  3. Controlled Flight into Terrain  4. Runway Incursion  5. Airborne Conflict  6. Ground Handling  7. Fire

VERY DISAPPOINTING NOT TO INCLUDE AIRWORTHINESS  No consideration of Airworthiness & Safe Maintenance Practices.  A safe Flight starts with an Airworthy Aircraft.  First we had to do Hazard Identification.  DAW have adapted the Shell Aviation SMS concept of ‘Hazardous Event’ categories associated to different phases of Aircraft Operation.  Hazardous Events - HE1 thru HE 28  Now we are expected to determine SPI’s & SPT’s.

FIXED WING HAZARD LOCATIONS 15,00 0 ft

Helicopters

Tiltrotors

Hazardous Event vs Location A. Aircraft on Ground Stationary

Hazardous Event vs Location C. Aircraft in Motion – On the Ground

Hazardous Event vs Location E. Aircraft in Motion - Airborne

Hazardous Event vs Location F. Aircraft Undergoing Maintenance

Location / Phase

Maintenance & Engineering Significant 13  HE 15 Release of an unairworthy aircraft to service  HE1 Loss of containment of Fuel / Oil  HE4 Uncontrolled GSE to an aircraft  HE8 Exceedance of an aircraft limitation  HE10 People in proximity to running engine / propeller  HE14 Flammable material in proximity to a source of ignition  HE16 Static out of balance situation cause by incorrect weight distribution

Maintenance & Engineering Significant 13  HE17 Unplanned release of a suspended load during maintenance  HE5 Health, Safety, Environment  HE25 Actions or implications of people & their inter face with work environment  HE26 Actions or in-actions of management at the appropriate time  HE27 Lack of awareness  HE28 Damage to aircraft or injury to person whilst working on aircraft

INDICATORS - CAR 145 Boeing MEDA Installation error • Servicing error • Repair error • Maintenance/Test error • Foreign Object Damage error • Airplane / Equipment damage error • Personal injury error • Engine ground run error • Certification (CRS) error • Inadequate Data error • Tech Log data entry error • GSE Maintenance error • Human Factors – loss of spatial awareness • Maintenance overrun error •

INDICATORS - CAMO Overdue / non-compliance of AD error • Aircraft Maintenance Program (AMP) compliance • error Overrun of maintenance / LLP error • Maintenance Data error • Airworthiness Review error • Aircraft Certificates / Documents error • Certificate of Release to Service by contracted • 145 MRO error Aircraft Technical Log data error • Unapproved Modification error • Deferred Defect error •

Finding the Applicable Measuring Criteria  Airline - Per 100,000 Flight Hours  Private Operator, Low Utilization – number of Work Orders issued  Light Aircraft, Pre-flights, servicing tasks – number of flights.  Helicopters – number of Work Orders issued  Percentage of errors that could have/should have been prevented

Only Events Count  Only Events within your control count – If there is something that could have been done – it’s something that should have been done  145 Errors & CAMO Errors – Your errors  Outside of your control but can track!  Bird Strikes – report to Authority  Errors / Damage to aircraft at/by MRO  Errors / Damage by Ground Handling Agent  Design Fault

What if’s – Permutations of 28 HE and 54 Threats = 5.7 x 10 ⁴⁴ Maint – 1.7 x 10³ ⁸ Now is History 5 Why’s = Root Cause

Extract from DAW Newsletter  63 maintenance related reports submitted last year  32 were ‘Potential Hazards’ 30 were ‘Events, 1 Quality issue.  Of the 30 Events 21 were out of our control (component failure, damage from Bird Strike etc)  9 Events were considered to be preventable by DAW  Of those 9, 2 of them (7%)were CAMO errors  7 of them were CAR 145 errors

Of those 9, 2 events (7%) were DAW CAMO errors  Maintenance Overrun – A6-GGP portable ELT battery not entered into RAL correctly. HE15, Planning. Indicator: Maintenance Overrun error.  Maintenance Overrun – A6-HRS CVR ULB battery not entered into RAL correctly. HE15, Planning. Indicator: Maintenance Overrun error.

The other 7 events (23%) were DAW 145 errors A6-RJ2 #2 Engine outboard fire bottle squib wiring cross connected.  HE15, Aircraft at MRO, ROSI. Indicator: Installation error. A6-RJ2 Fixed ELT not programmed after maintenance task. HE15,  Aircraft at MRO. Indicator: Maintenance error. A6-HEH flown with overdue maintenance task. HE15, Aircraft  Operational away from base. Indicator: Maintenance Overrun error. Personal injury – cut head. HE5, DAW Ramp/Apron. Indicator: personal  injury error. A6-RJ1 inadvertent slide deployment. HE3, DAW Ramp/Apron. Indicator:  Human Factors – loss of spatial awareness. Stores personnel crashed buggy into roll-up door – no injury, just door  damage. HE5, Stores. Indicator: Human Factors – loos of spatial awareness. A6-HRS maintenance overrun – Mag plug inspection. HE15, Aircraft  Operational away from base. Indicator: Maintenance Overrun error.

Target – Encourage more reporting  Report more Potential Hazards & Events  Target is to reduce the percentage of DAW errors  Educate / Encourage our MRO’s to do the same.

What do you think ?  What are your Indicators ?  What measuring criteria is applicable to your operation ?  How & What are you tracking? ANDREW LAWSON lawson@daw.ae

General Civil Aviation Authority of UAE CAR M Presentation Airworthiness Consultative Committee 19 May 2016 Hatem Dibian-Manager CAMO and Air Operators & Henry Angel -Senior Inspector CAMO & Air operators

Objectives  An Overview of the ICAO State Letter and the new proposals  To give an overall view of current and proposed changes  Overview of the up and coming changes in the ROSI structure  SMS update  CAR M update

ICAO State Letter AN7/1.3.105-15/78 27 NOV 2015  Title: Proposals For The amendment of Annex 10, Volume IV Regarding Surveillance And Airborne Collision Avoidance Systems  Response from the member states was required by 29 Feb 2016

New ICAO Requirements  ICAO has developed new requirements with regards to : • ADS-B ( Automatic Dependent Surveillance -Broadcast ) the implementation date is November 2018 • SSR ( Secondary Surveillance Radar) • ACAS ( Airborne Collision Avoidance System)  Operators are advised that this has a financial impact on their operation and are required to communicate with the GCAA in order to decide on an acceptable implementation date

ICAO State Letter AN7/1.3.105-15/78 27 NOV 2015  UAE will implement the new Transponder requirements (ADS-B ) OUT by 2020  (ADS – B) OUT for surface vehicles will not be mandated in UAE

CAR OPS-1.830 Extended Overwater Flights  The title of this rule was “ Life Rafts And Survival ELTs For Extended Overwater Flights”  Applicability “ All Airplanes of a MTOM over 27,000Kgs involved in Commercial Operations”  The requirement is : “ Life Rafts Shall be equipped with a securely attached ULD operating at a Frequency 8.8 KHz”

CAR OPS-1.830 Extended Overwater Flights  Exceptions: • “ Unless the Airplane is operated over routes on which it is not at a distance of more than 180 NM from the shore OR • The Airplane is equipped with automatic means to determine the location of the point of end of flight within 6 NM accuracy (following an accident where the A/C is severely damaged) ” .

CAR OPS-1.830 Extended Overwater Flights  AMC to CAR-OPS 1.830 ( d ) • “ ULD performance requirements should be equivalent to SAE AS6254 Minimum Performance Standard for Low Frequency Underwater Locating Devices (Self powered), or equivalent documents. This automatically activated underwater device should operate for a minimum of 30 days and shall not be installed in wings OR empennage”

CAR – OPS 1.605 GENERAL  An Operator must establish the mass and the center of gravity of any aeroplane by actual weighing prior to initial entry into service and thereafter at intervals of 4 years if individual aeroplane masses are used and 9 years if fleet masses can be used. The accumulated effects of modifications and repairs on the M&B must be accounted for and properly documented. Furthermore aeroplanes must be reweighed if the effect of modifications on the M&B is not accurately known.

Proposed ROSI Restructuring  Safety Occurrence Management Team will be formed with the main functions to: • Classify the occurrences and, • Develop reports periodically for SSP analysis purposes,  Events in CAAP 22 will be classified into two categories “ CAT 1 & CAT 2”

Proposed ROSI Restructuring • CAT 1 Are reportable incidents which are deemed to be critical and required to be reported to the GCAA and routed to the concerned department Inspector and the Safety Occurrence Management Team within 72 Hours , • CAT 2 incidents are to be reported to the GCAA within15 days from the date of occurrence with an initial investigation report as necessary.

Proposed ROSI Restructuring  Examples of CAT 1 Events are: • Loss of any part of A/C in flight, • IFSD  Examples of Cat 2 Events are: • Failure or defects of passenger address system resulting in loss or inaudible announcements

Proposed ROSI Restructuring  In CAT 2 events: • Inspector will not be notified, • Reporting requirement to GCAA within 15 days from occurrence, • Event will be handled by the Safety Occurrence Management Team, • The Team will analyze the event and decide if further investigation is required.

SMS audit standardization  SMS audits will be standardized throughout the UAE  Focal Inspectors from the GCAA will be appointed to conduct these audits thus providing a uniform and standard process across the board.  Check lists and procedures are being developed to accommodate the above  An SMS Enhancement working group was established after the last ACC Meeting in order to improve the understanding of SMS and instill best practice amongst UAE organizations.

SMS Implementation  A new check list is being developed to provide oversight on the effective implementation of SMS  The check list will provide a standardized approach and insight on the operators understanding and implementation of SMS

SMS Reporting  The GCAA will issue a new IB in order to define the Safety Performance Reporting of organizations’ SPIs.  Quarterly Report submissions dates will be required.  A report template will be published with this IB , where airworthiness and flight operations SPIs are included  If the organization wishes to use a different format then it should be acceptable to the relevant inspectors.

Subpart I Privileges  The requirement for all operators to hold subpart I privileges is expected by the end of 2016  FTOs are expected to have the subpart I privilege by June 2017  In general all organizations are required to be prepared for this introduction and to either have the privilege themselves or subcontract the function to an approved CAMO

CAMO - FEES  The GCAA intends to begin charging a fee for CAMO organizations  IB 14/2006 makes reference to the above.  The fee structure follows a similar logic used in the charges for CAR 145 organizations .  The fee structure is based on the number of aircraft types operated by an organization.

IB 11/2016 ARC Review Staff Training /Workshop  The GCAA has become aware that different organizations are employing varying standards in the process of ARC renewals. The GCAA intends to conduct a mandatory workshop to all ARC review staff instilling best practice procedures and processes required to be followed prior to the issuance of an ARC.

Thank you Your time is greatly appreciated. We look forward to working with you. @GCAA_UA E FACEBOOK.COM/GCAAUAE GCAA.GOV.UAE GCAA_UAE

THE UAE AIRCRAFT REGISTRY

AMENDMENTS TO CAR PART V, CHAPTER I Amended provisions:  Clarification on which provisions of CAR Part V Chapter I are applicable to Light Sport Aircraft – it makes reference to CAR Part II Chapter X on Light Sport Aircraft Regulation.  Clarification that IDERA letter can also be issued in favor for the aircraft owner (IDERA letter to be a requirement to register/amend COR when registered owner and operator are not the same party)  Registration plate for balloons shall mention: registration mark, aircraft model and name of aircraft owner & operator. 19 May 2016 94

AMENDMENTS TO CAR PART V, CHAPTER I Amended provisions:  Back side wording of the COR will be removed. Reason: • To avoid delay in the process • Duplication of the same requirement Note: Back side of the COR shall be completed when required  The is no need of notarization of no objection letter or any other letter if: • The signatory is the person who has power to sign (e.g. the person mentioned in POA) • The original letter is filed with the GCAA for records 19 May 2016 95

AMENDMENTS TO CAR PART V, CHAPTER I New provisions:  The registered operator shall ensure that any agreement recorded with the AR is valid for the whole period the aircraft is being operated.  Requirements to be met when aircraft owner is a Trust.  Rules for registration mark and mode s code: a year validity period, cancellation of mode s code, changing mode s code. 19 May 2016 96

AMENDMENTS TO CAR PART V, CHAPTER I New provisions:  A reserved registration mark and mode s code can not be used unless the aircraft is registered being granted with a COR.  The aircraft registration mark and plate shall be replaced and removed it. NO need for proof. Reason: • To avoid delay on the process • It will be responsibility of the aircraft owner/operator to ensure that the registration mark and plate are removed. 19 May 2016 97

AMENDMENTS TO CAR PART V, CHAPTER I New provisions:  Affidavit: a letter stating that the owner (applicant) can not produce a required document. Requirements: • Original and signed by the owner or his authorized representative • Notarized  New AW Form AWF-ATC-001 Replacement of Certificate (no e-services). This form is to be completed to replace (re-issue) any aircraft certificate. Requirements: • Complete Form AWF-ATC-001 • 500 AED fee: to be paid at the front desk. 19 May 2016 98

AMENDMENTS TO CAR PART V, CHAPTER I Upcoming amendments:  AW forms are being updated. 19 May 2016 99

Cape Town Convention Academic Project (CTC-AP ) UW Oxford UNIDROIT Advisory Board Joint Auspices Database A ICAO Academic Journal B Cooperation Project Conferences C OTIF Teaching Founding Sponsor D materials Law & Others AWG E economics Compliance A. Legislative history, F Reporting implementation materials, cases, Annotations of G administrative action, academic ‘OC’ writing, practitioner materials, registry materials now available E. With Business School and/or on website Economics Department B. Yearly. Cutting edge/multi- F. Iterative reporting to provide incentives discipline to governments and information to C. Academic conferences financiers and investors D. (i) For use in range of courses, G. Authorized annotations to address e.g., TCL, IBT, developments and issues comparative/international law, NB: All open source, electronic, and free and secured transactions; (ii) 19 May 2016 100 detailed Cape Town materials