Military Airworthiness Authority

[OilCan]

If the goverment backed CAA says NO, the government revokes the independently backed operators licence to operate.

If the government backed MAA says NO, the government revokes the government backed operators licence to operate.


Conflict of interest? or simply shuffling the problem up one level? :confused:

[Chugalug2]

OilCan, you have done what I have striven not to do over the last year or so, started a separate thread re an MAA. Your prerogative of course, but the glaring problem here, IMHO, is not the difficulty of setting up and agreeing the Terms of Reference of such an Agency which will be great, but the overwhelming proof in the various threads on this Forum that the present arrangements have failed, and fatally at that. It’s bust and I believe beyond fixing while the operator is its own regulatory authority. Self regulation, that very British disease, never works as it purports to but ends up covering the backsides of those who fail their customers, clients, users etc. In commerce that can be expensive, in aviation it's a road that you travel at your peril and that of others as well.
The role of an MAA would be to see that UK Military Aircraft are supplied fully airworthy, i.e. in accordance with UK Military Airworthiness Regulations, and remain so. It would be for the MOD to decide which aircraft it wants, which systems they need, and how they should be maintained. If any of those decisions adversely affect airworthiness then the MAA will say NO, as you put it. The emphasis would be on prevention rather than cure which seems to be the way things happen now. If the MOD can, as it has to, involve private commercial bodies in these decisions, then I see no reason why a separate regulatory body should not be involved as well. Personally I am not looking beyond the provision of Military Airworthiness. That is where the problem is and where an alternative solution must be found. That is enough to be going on with. The problems will be great, but the prize would be Airworthy Fleets, well worth the effort surely?

['Chuffer' Dandridge]

The UK CAA are not 'backed' by the government. They are an independant regulatory body, and rightly so, their existance stems from the Civil Aviation Act of 1982....

Can you imagine if Gordon Brown's mob had their fingers in the CAA pie? It would be even more disorganised than it is now!:sad:

[OilCan]

Chug

I'm sorry if I upset your strategy. My intention was to reduce the parallel discussions on the Nimrod thread, obviously without success! :ugh: Frankly, I don't know enough either way to form a balanced view, as chuffer has already pointed out.

I think my final point remains valid however.

On the other hand, removing the military career ladder from the process does have some merit, but would inevitably lead to duplication of effort in certain areas. Paying for the same think twice is not likely to appeal to any government.

Oilcan

[Chugalug2]

If the thing that they would be paying twice for, OilCan, is Airworthiness, then better to pay twice and get it, than pay once and be denied it as now! In any case many of those concerned with the process would continue doing so, though under the MAA rather than the MOD. The senior military officers (mostly RAF?), who one would suppose had the greatest vested interest in securing airworthiness seem on the whole, from reading the Nimrod Hercules and other threads on this Forum, to have had very little success in doing so. They never will be missed, they never will be missed, to quote G&S. On the other hand those serving personnel wishing to pursue that goal would have the opportunity to a possible second career in the MAA.
As to my strategy, I have none, other than to see the RAF fly airworthy aircraft. The battleground for that must be in the threads dealing with specific cases of unairworthiness, eg the Nimrod one. It seems to me pointless to simply run a thread calling for another pillar of bureaucracy. It may well not appeal to the government, as you say, it doesn't even appeal to me! But if that's what it takes to make the military fleets airworthy, then go for it I say!

[Rigga]

IMHO
As far as a "military airworthiness authorities" would be concerned, the main problem of having 'Airworthy' aircraft would be the restrictive practices that come with that qualification - Health & Safety for aircraft....
- All of a sudden you won't be able to:

Rob aircraft in long-term storage or Gate Guardians (I've done that twice!) or
Refit an item that you know is U/S "For a bit longer" IAW the Sengo's say-so.
Or just stop-drill that little crack, or
Put a pre-mod one on because you can't get a post-mod one, on the Sengo's whim, or....

Get the picture?

[Occasional Aviator]

I disagree. The reason why the military regulates its own airworthiness is precisely so such things can be done. Military airworthiness is different to civilian airworthiness, as there are situations where we need to be able to accept risk - such as for tasks that save life, or are vital to the national interest. The problem comes when these risks are taken under pressure to produce and by people who are not qualified/authorised to assess or take the risks. In fact, a single military airworthiness authority would be a good idea IMHO, rather than three single-service chains (plus D Flying's) that do things subtly differently and have all (except D Flying) had their independence from the front line significantly eroded in recent years.

[John Blakeley]

The old Defence Aviation and Safety Centre (DASC) has now become the Directorate of Aviation Regulation and Safety (DARS) with a web site at

http://www.mod.uk/DefenceInternet/AboutDefence/WhatWeDo/AirSafetyandAviation/DARS/

Its “mission statement” says:

“The DARS is the pan-Defence policy, regulatory and auditing body within the MoD Central Staffs and is the MoD focus for Aviation Regulation & Safety issues.

The mission of the DARS is to enhance operational capability by improving Defence Aviation Regulation & Safety

Key Roles:
• To formulate, regulate and validate Defence Aviation Regulation and Safety policy as directed by the MOD Aviation Regulatory and Safety Board (MARSB).
• To provide Aviation Regulation and Safety advice to the Service Chiefs of Staff, Defence Equipment and Support (DE&S), and also to the MARSB.
• To provide Aviation Regulation and Safety advice to Commands, Aircraft Operating Authorities, Release to Service Authorities.
• To provide Aviation Regulation and Safety advice to other Government Departments, civilian and military agencies, NATO, Foreign & Commonwealth and Partnership for Peace countries as well as to industry.
• To act as the focus for Aviation Regulation and Safety matters in the MoD.
• To provide common, high-level Aviation Safety education and publicity.”

The key word here seems to be “regulate” – but will it have the resources and authority (it is led by a "purple" 1*) to do this. Perhaps another PPRuNe contributor knows and can comment.

However it is interesting that the word airworthiness does not figure in its mission statement and I have not yet found it in the (limited) selection of their linked documents that I have looked at.

JB

[Occasional Aviator]

John,

That is because the DARS (and DASC before it) regulates and makes policy. Airworthiness is managed by the Service Airworthiness Authorities who are officially the head of the Service Operations Branches (ACAS for the RAF, but delegated to DAAvn in the Army and I believe to Fleet ACOS AV in the RN - although the last one may be out of date).

If this has changed in the last year or two, please someone let me know!

[Chugalug2]

Military airworthiness is different to civilian airworthiness, as there are situations where we need to be able to accept risk - such as for tasks that save life, or are vital to the national interest. The problem comes when these risks are taken under pressure to produce and by people who are not qualified/authorised to assess or take the risks.
Good post OA, if I may say so. I'm not trying to inflict Civil Airworthiness on the military, but airworthiness in accordance with Military Airworthiness Regulations, which patently cannot be relied on now. That has to change and independence of the MOD is the key. You can call the resulting setup what you wish. No doubt it would be an anagram of those listed in your later post! :)

[tucumseh]

Further to John’s post, this is not the only rebranding that is going on. ADRP are now DMSD (don’t ask). Suffice to say that the regs have always said “If you have a query on Airworthiness policy, contact ADRP” (as Secretariat to the Defence Airworthiness Group).

Now, the Airworthiness “system” is labyrinthine to say the least, with committees galore; all doing sterling work. The policy and regs they issue are, by and large, robust. But the practical IMPLEMENTATION is where the day to day problem is.

A practical example. I once went to ADRP for advice on how to deal with the fact that our mutual 4 Star had declared airworthiness optional, resulting in my aircraft being no use to man or beast; the response was “get another job”. (Friendly advice, well intentioned). As in many walks of life, there is NO WAY someone 6 or 7 grades down is going to over-rule the big boss or even challenge him. Its policy you see, and Civil Service rules say that if you don’t like a policy decision you accept it or resign. The problem is if you accept and implement that policy knowing that you are making a false declaration, you have a moral dilemma (in addition to committing a fraud). Compounded when Min(AF) supports 4 Star.

Is it little wonder MoD has problems?

PS – I chose otherwise. I ignored 2 and 4 Star and made the aircraft safe. Those here who were at Boscombe at the time know exactly what I'm talking of. But, you can get away with it on your own aircraft, but can't force other offices to do the same. They are the ones with blood on their hands.

[John Blakeley]

OA,

Tuc has already covered part of what I would have said (clearly he stays up later than me!), and I do not disagree with the underlying comments you make about the military role - but I do question whether we are misusing terms. As I wrote on the Nimrod thread a few days ago as far as I can see the principles of military and civil airwothiness should be the same - the risks are different not just because the roles are different but because the military relies on different equipment some of which is operating in an inherently more risky role - even as an engineer I have experienced the thrill of terrain following radar ride in a Tornado, and I wouldn't want to try it in a 737. However, for both military and civil operations the achievement of the mandated airworthiness standards starting from the design through to day to day maintenance is, I suggest essential. It is here that the new DARS and the CAA part company in a big way - look at the CAA web site and their involvement in the regulation of airworthiness and you will see what I mean. Yes, for both military and civil airworthiness the final "guarantee" that the aircraft is airworthy and "fit for purpose" rests with the User, but the regulation of that policy does not. Indeed for the MOD it should not either - as Tuc has said the procedures are in place but where are the teeth (and funds dare I say despite MOD's "promises" that safety is paramount) to enforce it. The procedures have not been followed on numerous occasions with the crew of XV 230 paying the ultimate price - by the RAF's own admission.

Yes the military has to accept the higher risks of military flying in both operations and training, and at the end of the day the User probably has to have the right to make his own final decisions even on airworthiness risks if the operational imperative is there - but these decisions should be informed ones - not for example being made by unqualified 1 and 2* supply officers or administrators or driven solely by money as seems to have happened quite a lot recently. Such decisions should be the exception not the rule and also, I suggest, need monitoring so that an operational imperative to operate an aircraft not reaching the mandated airworthiness standards, such as the Chinook Mk2 being flown against the advice of the flight test authority, is only used for vital operations and not to fly 25 passengers across the country - an even worse loss of life than XV 230!

If the DARS has teeth (and qualified resources and funding, and even the ability to report direct to the SofS perhaps) as per the word "regulate" in the first paragraph of its mission statement maybe this will fit the bill - I wonder why I have doubts. If for no other reason MOD is going to have to get this right before it faces even larger compensation claims that it probably faces already. Some may not like it, but comparisons with the last century's World Wars are irrelevant. We are not in a situation today where a failure to have equipment that is fit for purpose can be ignored because "the military are paid and expected to take these risks". It is not so comfortable for the MOD and even the day to day decision makers anymore for all sorts of reasons - but having poor kit or unairworthy aircraft should not be adding to the risks that cannot be avoided - we do not have enough resources to go down that road anyway! There is nothing operational about losing an aircraft and, worse, a crew in the circumstances that XV 230 was lost.

JB

[Blacksheep]

Given that there are already military airworthiness requirements and an inspectorate covering civilian involvement in military design and repair organizations, what would a military MRO look like?

What level would you set the Air Operator's Certificate - Command? Squadron?

If you have an MAA setting the rules, who within the military maintenance organizations would be responsible for QA?

What....

The questions are endless, but military airworthiness is quite different from the civilian version for a very simple reason. Civil operators are private companies, trying to make a profit from carrying people who, having no knowledge of aeronautical matters, are unable to make informed choices.

[tucumseh]

I’ve been asked to expand on my comment on the 2 and 4 Stars saying airworthiness is optional. Gladly.


The ruling was that a dependent project (for example, one which is delivering a pre-requisite kit to the main aircraft programme, and which is required to demonstrate the aircraft is airworthy and safe before transferring responsibility) can;


Refuse to carry out systems integration, leaving the system of systems functionally unsafe
Pay off the contract in full despite the important part being ignored
Not modify the simulator, provide spares or tech pubs etc (any one of which should prevent MAR)
The main aircraft programme shall pay the same company again to do the work they should have done in the first place (and find the money from their existing budget, so something else must give)
When the company fail (again) pay yet another company to do the job properly.

Now, clearly, if this was blanket policy no aircraft would fly. In practice, the ruling was confined to staffs that had been earmarked for greater things and needed the box ticked to say they’d (mis)managed a project. (Whether they were successful or not is immaterial – MoD don’t measure project management competencies in terms of achieving time, cost or performance). In my opinion this is actually worse, because the aircraft programme manager (as opposed to equipment) who ends up having to fix it doesn’t know where he stands. If it was blanket policy you’d just assume equipment offices weren’t going to do their job (in the same way you always assume support offices won’t) and make sufficient provision in terms of money and time. But what you have to do is assess your dependencies and the people you are dependent on, find out their background and ask what they will actually deliver. Those I refer to usually don’t have a clue so you must engage their contractors – or in the above example, the contractors who SHOULD be under contract to integrate, but weren’t even told what was happening. This then becomes the first contract of your programme – Risk Reduction. The 4 Star got his airworthiness delegation direct from Secretary of State.

All the above is open source obtained under FoI, from my MP and in personal letters from the 4 Star. Like I always say, start at the top. I hope you didn’t get bored.

[JFZ90]

Tuc,

I'm not sure I follow your point below...

It is alledged that there were 2 and 4 Stars saying airworthiness is optional


and yet it seems that in this case, whilst something was missed, MoD in the round did infact...


pay the same company again to do the work they should have done in the first place

and then


pay yet another company to do the job properly.

Whilst this potentially says something about project & contract management (your example implies MoD paid 3 times for the same thing), you could argue this does not mean they think airworthiness optional - infact quite the opposite they spent 3x the budget to get to where they needed to with respect to engineering it properly.

From the above, was the job infact eventually done properly as you state? If so this is at odds with the statement airworthiness was optional - it sounds more like a debate about which team should be responsible for what, and the issues this can create.

[tucumseh]

JFZ90

My point is that people refused to deliver airworthiness despite it being an endorsed requirement, and this was specifically condoned, in their case, by the 2 and 4 Stars. I don't think I was wrong using the word "optional" because this is precisely how they approached it.

The initial contract (in this example - there are others but this is the one I can talk about because I have the info officially) was barely adequate. It clearly said "integrate the systems". This was attempted but failed miserably, as reported by Boscombe. The people in question had a choice - make the aircraft safe or pay off the contract and walk away. They chose the latter option. I didn't think they should have been permitted that option, but CDP disagreed. Hence, to my mind, he ruled achieving airworthiness was optional, to those individuals.

I also think the company morally bankrupt (a legal person will tell me if they committed fraud) because they knew they had done wrong (the Boscombe report was the most damning I've ever seen) and compounded this by gleefully quoting the aircraft office (even more) to make the same mistakes again.

When the correct companies were properly contracted they did the job effortlessly for a fraction of the price. And I really do mean a fraction.

Who was wrong?

[Occasional Aviator]

I can only agree with tuc. I have seen exactly the same things happen when one IPT wriggles out of it's airworthiness (and moral) responsibility to another - and were permitted to do so because there was not sufficient oversight to make sure these things did not fall between the cracks. Sadly, despite what we say about safety, money is available only for capability, not airworthiness per se.

John Blakely,

I think we are in violent agreement - sorry if my brief post earlier did not make that clear. I too feel that DARS should have 'teeth' and be able to enforce standards. I would add one more thing in to the discussion though. You say that you feel that the principles of military and civil airwothiness should be the same - the risks are different not just because the roles are different but because the military relies on different equipment some of which is operating in an inherently more risky role and if I read you correctly you feel that DARS should regulate airworthiness in the way the CAA does.

I feel there is a subtle but important difference in the principles of military and civil airworthiness. In my experience, civil airworthiness relies much more on enforcing particular regulations and building/maintaining to particular standards, and less on what the military should be concentrating on, a systems approach to risk management. Now I know that this is practised in civil aviation, mostly at the design stage and to a very high level, but the point I want to make is this. If you buy an airliner, you are very likely to use it in exactly the way the manufacturer envisages. With military aircraft, it is difficult enough to give a designer a clear idea of what you intend it to do at the start of its life, much less how you will actually be using it 20 years down the line. This can have some really serious consequences, like 10000 hour lifed parts wearing out after less than 100 hours because the aircraft is being flown in a way the designer didn't envisage.

As you rightly point out, for both military and civil airworthiness the final "guarantee" that the aircraft is airworthy and "fit for purpose" rests with the User and I think this is probably the key weakness of the military system - the sqn commander who tells his crews that they should all fly at Vmax is in my opinion creating a much bigger airworthiness issue than the SEngO who authorises fit of a part-worn component - and at least the SEngO is aware of his airworthiness responsibilities in this sense.

This is probably exactly what you were getting at when you said that the decisions should be by informed people and I do agree with the main thrust of your post though. The example of Chinook Mk 2 is spot on.

[Safeware]

Tuc, OA, JB et al

As regards DARS, ADRP, rebranding etc , did you know Air Cdre Baber is now Director Air Systems responsible for Design & Modification Suport Division (DMSD), Continuing Airworthiness Support Division(CASD) and Test & Evaluation Support Division (TESD):


Provided governance framework of Policy, Rules and Standards to assure the airworthiness of aircraft and helicopters acquired or in use by the Armed Forces, and the quality of products and services procured by the Ministry of Defence. Leadership of a 350-strong organisation (predominantly civilian), dispersed geographically throughout the UK.

via Google, from his entry on a professional networking site:
http://www.linkedin.com/in/georgebaber

Will he be the man to give the system the teeth it needs?

I hope so.

sw

[Mick Smith]

Sorry Safeware. Are you saying the man who put his hand up and said he was to blame for Nimrod not being safe is now in charge of ensuring the safety of every aircraft the RAF, Army and Navy fly?

[Safeware]

Mick

It's all out there if you look for it. Google "george baber airworthiness" to get the networking page. There are other interesting links on this page such as the one titled "Single Skills Framework Air Worthiness Competence Set November ..."

Then google "director air systems" to see where he fits in, including browsing around the AOF: http://www.aof.mod.uk/index.htm

sw

[John Blakeley]

OA,

I am happy to violently agree with your last post!

JB

[Rigga]

From Chug's Post no. 10...

"Quote:
Military airworthiness is different to civilian airworthiness, as there are situations where we need to be able to accept risk - such as for tasks that save life, or are vital to the national interest. The problem comes when these risks are taken under pressure to produce and by people who are not qualified/authorised to assess or take the risks.

Good post OA, if I may say so. I'm not trying to inflict Civil Airworthiness on the military, but airworthiness in accordance with Military Airworthiness Regulations, which patently cannot be relied on now. That has to change and independence of the MOD is the key. You can call the resulting setup what you wish. No doubt it would be an anagram of those listed in your later post!"


...My earlier point being that, to maintain a 'real' airworthiness status of operational aircraft, the current practices of ignoring or refitting U/S parts, or conducting unauthorised repairs, will be deemed illegal EXCEPT for genuine operational reasons - not just for the sake of training timetables or "Excercise" sorties.

The military exceptions to standards of airworthiness should ONLY be for the need for military support during hostile actions, not for peacetime actions.

Whatever your reasons for rushing into meeting the needs of Excercise and Training Sorties - the airworthiness of the aircraft YOU FLY should not be jeopardised for "practice" reasons.

By using proper airworthiness criteria the supply chain could be made to move at the right speed to meet new logistical demands (you'll get the spares held forward - where they are supposed to be, instead of being just too late.)

Yes, initially this will mean sorties will be cancelled due to engineering shortages - but you can't have it both ways - you either fly 'airworthy' aircraft, or wartime military aircraft.

...Incoming!!!

[Chugalug2]

the current practices of ignoring or refitting U/S parts, or conducting unauthorised repairs, will be deemed illegal

Surely such practices are contrary to existing Military Airworthiness Regulations already, Riga? If not they damn well should be, unless in accordance with the MEL! It's a big enough challenge to ensure that the military be supplied with aircraft that meet Military Airworthiness Regulations which patently does not necessarily happen now. That the military should then make them unairworthy by such practices is totally unacceptable, genuine operational requirements in wartime conditions excepted and open to MAA scrutiny.

[Rigga]

....If you listen carefully - you'll hear a penny dropping far, far away.