Nick, what a great presentation. The accident statistics you use support your arguement, and I find that both your arguement and the statistics are entirely consistent with modern error management theory:
Identify the problem.
Identify the systemic failures that led or contributed to the problem.
Engineer out the failure points identified. (Nick's arguement)
If you cannot engineer it out: provide significant warning or awareness signs for the impending hazard.
If you cannot adequately warn people, train them how to cope with the situation.
If training cannot adequately protect them, don't do it.
In otherwords, training around the problem is the poorest of the fixes available. I have had it related thus:
Problem: workers injured falling down slippery stairs on way to basement.
Most effective fix: identify and stop source of slippery-ness, coat in non-skid surface, and provide banister.
Less Effective: ensure stairs brightly lit. Paint top of each riser with yellow stripe, provide warning sign at top and bottom of stairs.
Least effective: give people practice at walking on slippery stairs, teach them how to effectively break a fall.
Remaining alternatives: relocate basement stores to same level, or build lifts (ie do not do task).
ron-powell: I am pleased that you have mentioned NVG. Why did you not feel that it was a CFIT defence Nick? Or was it just less significant than a 24 hour defence such as EGWPS?
Also ron, the reason you can fly unaided at night without the rad-alt, yet not with NVG is the rule V technology development conundrum. With the introduction of NVG into civil helicopter operations coming some 70 years after night flying was attempted, there was a much greater knowledge base to work off when dreaming up the rules. Rad-alts are also a CFIT defence device, albeit an early one that fits into the less effective warning area of failure management. Thus they were incorporated into the NVG requirement as a CFIT defensive aid. Had night unaided ops been dreamt of after the invent of the rad-alt you can bet your bottom dollar they would not be an optional item for night unaided. Though I think that in both unaided and NVG, they should be on the MEL.
The question is then, given that we now have the knowledge of the rad-alt technology and it's defence against our industry's biggest killer (CFIT), why do we have to wait for our mama (FAA/CAA/CASA/etc) to tell us it is a smart requirement? Can we not make these reasoned restrictions without having to be told? Or more importantly, can we responsibly have items like that MEL unserviceable without stretching the intent of the MEL to get us home? Are we that responsible yet? Or must our mama make it black and white no-go to ensure we do not abuse her trust?