MAA v Mil Flying Clubs

[Could be the last?]

There is a great deal of work currently being undertaken wrt risk management on the various ac fleets that Defence operates. Can someone shed light on what affect this is having on the Flying Clubs, if any, and what compliance they have to adhere to when operating from a mil airfield?

Just asking:rolleyes:

[blagger]

That's quite a specific question - what is your interest / angle?

[Rigga]

...same rules as everyone else - and the local airfield rules, like everyone else does on their local airfields.

[Corporal Clott]

The MoD have a responsibility to provide a safe operating environment (ie. Govt Airfield) and the Association/Club have responsibility under the GAI to provide a safe club environment which complies with all the regulations (mil and civ). The airworthiness is the responsibility of the aircraft operator and is regulated by the CAA for all "Group A" aircraft (yes, I know Group A no longer exists for the purists!). So there is no Duty Holder responsibility/construct for the operation of civil registered aircraft for non-publically funded service flying club activity. Airworthiness is CAA business.

However, if publically funded, like civvy regsitered Grobs, Fireflys, gliders, etc... Then there is a Duty Holder in 22 Gp with an ensurance/assurance process - I believe this to be OC 3FTS? Airworthiness in this instance is MoD business but uses CAA regulations.

So the difference comes with "publically funded" and "non-publically funded" flying activity.

Make sense?

CPL Clott

[Could be the last?]

Makes sense, to a degree, and I understand the CAA compliance rules. However, with non-public funded flying clubs operating in such close proximity to mil ac, has the introduction of the MAA made a difference to the way they (the flying clubs) are operated? Does the OIC of such a club now become directly accountable for those within his club, much the same as a DDH?

[Corporal Clott]

OICs always had a 'duty of care' prior to MAA - so nothing has changed. The RAF Sports Board reccomended that Clubs become Ltd companies under Charity Commission rules - that way the individual is offered some protection, unless found negigent by the Coroner!

There's no DH rubbish going on as the airworthiness and trg is strictly CAA territory. Otherwise it would be a bit like the RAF insisting you had an FMT600 to drive your own car!

CPL Clott

[mosquito077]

An opinion. Flying Clubs operating at mil bases should be operating under CAA - JAA - EASA rules (bit of overlap at present). In many respects therefore the military concept of DH is nothing new in that an RTF or FTO must have an Accountable Manager. Having read a DH's delegation letter and considered its implications for that individual the outcome is very similar in obligation to the Accountable Manager. ASMS has been issued by ICAO long before MAA stood up and a scan through ICAO 9859 Second edition published in September 2009 will indicate to the reader many elements have been used in various MAA documents. ICAO and JAA Ops recommend operators with ac under 5700kg have an ASMS but it is not obligatory.

The key in my mind would thus be when the MAA begins examining flying clubs are they operating to a high enough standard of demonstrated safety equal to the rules being applied by MAA to military ac. Thus if a Club can show it has an Accountable Manager (normally HOT) and demonstrates an ASMS the pressure will be reduced. Risk management and insurance will be key pillars I think. If ASMS is seen as a box ticking exercise the risk of repeating the mistakes identified by HC will exist. Setting up an RTF or FTO with this system is well within our capabilities. Yes, more paperwork but most clubs having FOBs the meat of which can be used to create the key 4 elements of an SMS - I believe it needs brain power more than paper to sit down and ident as many risks as possible and how they are handled. This is not unhealthy if you accept MAA is with us and it will not be long before the spotlight is on Flying Clubs.

Just my views, hopefully helpful and I fully accept there will be many others. I just hope working together we can avoid closure of any mil flying clubs because of risk aversion.

Happy landings,

Mos :)

[Could be the last?]

007'

Thanks for that. The key area, as you have pointed out, is this ability for the club to demonstrate safety with an ASMS. I suppose that if a club can't do that or is not at a suitable level of 'assurance' the DDH/Stn Cdr will have no choice but to suspend flying activity, would he?

Since the introduction of the MAA, have those involved with flying clubs seen any noticeable changes or direction given on what ASMS to implement?

[mosquito077]

Could be the Last,

On your first para, absolutely agree with you - and in retrospect I should have mentioned that point too ie the 'civie operated club' is indeed in the hands of the Staish/MAA.

On your second para, not seen anything yet. However, I am trying to stay ahead of the drag curve by examining the MAA requirements and cross referring to what I see as the lead documents under which a military operated 'civie' flying club must operate. Thus when asked 'we' will provide our structure - Accountable Manager, CAMO documentation and SMS based on ICAO (JAA) which are very very similar to the DH/DDH concepts of MAA. As far as I can tell the DH letter grabs an individual by the short and curlies and makes it very very clear they are the person that will be answering the questions if anything thing goes wrong - sweeping and broad statement I agree but fairly close to the truth.

Flying Clubs thus need, I think, to demonstrate almost equal tear creating focus on ensuring accountability (responsibility). A good flying club should be doing this through the HOT and must of course provide paperwork to show it (the bit we don't like). I would welcome views but the ICAO (JAA) ASMS structure is virtually identical to MAA ASMS (except the term DH (closest in civie speak is Accountable Manager).

I therefore think the key will be demonstrating that the flying club is operating to comparable standards to MAA - which do exist in the civie world but do require some thought to put together. Some paperwork inbound therefore but if the brain power and paperwork is not there why should Staish/AOC allow the Club to continue? No one wants to be named in second HC style report.

I absolutely welcome views as these are my thoughts, as I am game on to listen. Perhaps anyone from MAA?

Mos:)

[Lima Juliet]

A bit like this then? RAF Flying Clubs Association - RAFFCASMS (http://www.raf.mod.uk/rafflyingclubs/Administration/raffcasms.cfm)

LJ :ok:

[blagger]

It's really not difficult - a flying club has to be run properly and accountable to CAA requirements, which for transition to an EASA ATO rather than a RF will require Ops Manual, SMS etc.. anyway. The DDH has to be assured and ensure that the flying club operating within his/her area of responsibility is properly run, governed and intregrating with the operation in a safe manner. A number of RAF clubs have already successfully been through this on both counts and things are running fine - recent audits have highlighted no concerns at all. PM me if you want to discuss in more detail.

[A and C]

Quite frankly I would hope that the MAA would have better things to do than mess with aircraft that are maintained and operated with far more mature safety oversight in this sector of aviation than the MAA can offer.

The UK CAA has overseen a general aviation industry with an accident rate that compares with the best in the world despite the UK having the most changeable weather conditions of all the best players in the safety stakes.

Having been around RAF flying clubs for some years now I have formed the opinion that post holding officers would do well to take the attitude that as long as the flying club is operating within the rules of the UK CAA & EASA they should leave well alone, I have seen misguided safety rules imposed by people who don't understand general aviation that have increased the risk of an accident by inposing rules that might be appropriate for service aircraft in a remote operational enviroment but not for a light aircraft flying over one of the most populated areas of the UK, surely this type of interference no matter how well intentioned exposes the person making the new rule to increased risk rather than showing a duty of care.

I look at the instructional staff at the RAF flying club that I am involved with and I see a breth and depth of experience that I doubt you would find on a squadron and I find the aircraft (used for instruction) maintained under EASA 145 just as are all the civil aircraft on MoD contracted work.

So I would ask those who are minded to impose more rules on RAF flying clubs to show a duty of care by leavening the running of the the clubs to RAF flying clubs association and the Regulation to the UK CAA & EASA, then if something dose go wrong it is happening under another compident regulatory authority and so not your problem as you have placed the oversight to persons better placed to manage the risks of this type of aviation.

[blagger]

A and C - while I understand your sentiment, the world has moved on. If operating from his/her airfield and airspace, the DDH (normally Stn Cdr) has a responsibility for the safe operation of the club and the safety of the people in it, not least because the safety of the other primary airspace users relies on it. That responsibility cannot be handed off. The clever way to do it is to recognise that EASA/CAA compliance is the means by which the flying club assures the DDH it is operating in a fit and proper manner.

[Lima Juliet]

Blagger

Fair but not entirely correct. Some RAF Flying Clubs operate at airfields without a DDH in post - Wyton, Halton, Akrotiri, Boscombe and Henlow all spring to mind.

So I beleive that A&C's points stand in these instances.

LJ:ok:

[Lima Juliet]

PS. Further to this, there are Military Stations without DDH's in post on that particular stations. All UAS's have a single Gp Capt DDH - he can't be at all stations at once! Plus he also looks after Air Cadet Gliding as DDH and there are 28 VGSs around the UK.

Also, the DDH for Tornado GR4 - does he live at Marham or Lossie? Or for Typhoon at Coningsby or Leuchars? Or the Hawk T1 DDH - Scampton, Valley or Leeming?

My understanding is that there is a single DDH for each aircraft type - or am I mistaken?

LJ

[A and C]

Quote-The clever way to do it is to recognise that EASA/CAA compliance is the means by which the flying club assures the DDH it is operating in a fit and proper manner.

I think that is what I was trying to say, I would not expext the Stn Cdr or any of his staff to absolve them selfs from the responsability for the safe operation of the club, but as you say this can be achived by simply mandating CAA/EASA compliance.

Unfortunatly it is not usualy the RAF way to accept another authority outside the chain of command, in this case it is the best way of doing things rather than spend time inventing a set of rules that the CAA/EASA has had in place for years.

The whole thing needs a light touch from the RAF just to make sure that CAA/EASA rules are upheld.

[Rigga]

As I said in Post 3 - UK Mil flying clubs MUST operate within the same rules as every other UK club PLUS the local airfield rules.

The only power any DH has over a 'civil' operation on a military airfield is to stop it flying if he/she doesn't like it - for any reason they want.

Changing/adding some local paperwork will perhaps give the required assurance to the DH that any other airfield/owner may also require. But, if the club does not comply with the CAA/EASA rules - even if the DH tells them its okay - it won't fly civil aircraft again. Simples!

HOW clubs comply with the rules is open to some interpretation - but still remains the CAA's final okay, not the DH's.

And its the local/airfield DH that has the power to stop a civil operation, not necessarily a Type DH (though he may throw his oar in too).

[mosquito077]

Blagger some good posts thanks for the info.

LJ - thanks for the link I had not seen that before. That SMS guidance is really useful and indeed I think answers many of the sub set questions in the posts above. That clear guidance on what Clubs should be doing answers in many respects Could be The Last? opening question -certainly at this stage.

A&C, not quite sure I agree with all your views, Blagger was right when he indicated we must move on as this is coming - that said LJ's link is really useful to make this as easy as possible.

General Point. I fully accept we operate under EASA and civie rules but is not the main point of this thread on how to avoid Clubs being adversely affected by fear of risk. Blaggers comments on successful audits was really useful and the link provided by LJ will help clubs - the key then as the RAFCAASMS doc states is putting in the effort, quote from RAFCAASMS:

Running costs. The establishment of the SMS requires staff effort to
draft and design the system. This will be followed by an education process for
all members. To maintain the SMS requires the appointment and the efforts of
your dedicated Flight Safety Officer (FSO) to oversee and manage the
processes of the RAFFCASMS.

I think this bit indicates why we need to move forward however the following quote indicates why it is not replicating safety systems used on ops which was posted by one observer:

Impact of operations. An SMS is not an impediment to the conduct of
efficient operations or to take the sparkle out of our hobby. The SMS operates
under the principle of risk management. By managing risk, the SMS allows the
organisation to conduct their normal operations, but in a more controlled and
safer manner than before.

Thanks for the helpful info.

Mos

[Could be the last?]

Leon,

Akrotiri does have a DDH!

[Whopity]

One Military Flying Club which had adhered to the EASA proposals was complemented on the Pre AOCs inspection, and told that other units on the station could learn a lot from them.