The concept of time (urgency) to embody a safety modification is dealt with in Def Stans 05-123, 125 and elsewhere. The decision manifests itself in the Class of modification.
For example, a Class 1 (Service) or A (Contractor) mod is
“essential for safety, the absence of which would involve, or may have already involved, the grounding of aircraft, the imposition on the use of aircraft, vehicles or ground equipment, or the shutdown of ground radio installations. They MUST be embodied, irrespective of the scrap or equipment downtime involved”.
In practice, the problem is failure to apply the mandated regulations. These regs require complete independence in that the decision must not be made by the proposer of the modification (normally the IPT or the Design Authority).
The regs still state that the proposer shall submit a “Cost and Brief Sheet” to the relevant HQ Mods Committee, the chairman of which holds a key person in the airworthiness chain. Such is the independence required that, should the Chairman be a MoD Technical Agency (the named individual responsible for maintaining the Build Standard) in his own right and his name appears on a modification proposal, then he must hand over the decision to the Deputy Chair.
It follows that if a mod is deemed Class A or 1 (when safety is involved, this decision is normally made within hours, before work commences to develop a mod) then the RTSA is automatically informed so that the question of grounding can be addressed.
Of course, this system was effectively scrapped in 1992 with the disbandment of most HQMCs. The mandated requirement for independent scrutiny was lost as the proposer was given authority to decide. That meant other factors (financial mainly) could cloud their judgment.
In practice, this immediately resulted in a raft of mods being hastily “approved”, many falling into the “nice to have” or complete bollox category. Then, a safety mod requirement would come along and there was no in-year money left, so you would get urgent mods deferred (by financiers, who were given the authority to over-rule engineering/safety decisions). Also, the HQMC would always ensure provision was made for support, training, embodiment etc. Not any more – the rush to buy the mod sets would be followed by a hiatus lasting years as squadrons, workshops and contractors were overloaded with unplanned work. Anyone at 2nd line sees the result on a daily basis.
If you read the criticisms in the Haddon-Cave report, very often the solution is to simply follow these regulations.
The above raises a few questions, including;
- Why, if the current practice does not reflect the regulations, have the latter not been changed? Answer – because formally changing them would bring senior staffs into conflict with PUS, whose mandated regs they ignore. D/Stan can’t bring themselves to amend the books because they would be forced to take sides, so just leave them. For example, the key Def Stan, quoted above, has not been amended since January 1990, yet every MoD Technical Agency should know it off by heart. Today, few have heard of it. It calls up 20 specifications instructing Technical Agencies on how to maintain, inter alia, safety, but try asking D/Stan for a copy of them. Why is it ignored? Because funding has been cut so far that IPTs very often simply cannot afford to maintain safety, so you get to the stage where new entrants are simply not taught what they are meant to do. They lose sight of the need for safety to the point, nowadays, where people are shouted down (or booed, as happened on Nimrod) and told not to waste money maintaining airworthiness.
- Has senior MoD management been informed of this critical safety issue? YES. The last time I did so was January 2000, to a 3 Star (DCE of DPA). He didn’t reply. Perhaps if he did the IPTs would have been directed to comply with the regs and this thread wouldn’t exist. However, I do realise that if he had done something he, in turn, would have had to choose between the regs and his boss (CDP) who had already ruled that functional safety was optional. But, a 3 Star gets paid a lot of money to make hard decisions and have quiet words in the boss’s ear. A mere project manager is paid peanuts to make decisions within his remit, and seek decisions outwith his own remit. Any breakdown in this process leads to …… Haddon-Cave.
Finally, and no apologies for labouring this point, but the H-C report contains absolutely NOTHING new that has not been notified to senior staffs and Ministers numerous times over the last 18 years. To quote MoD’s own Directorate of Internal Audit (June 1996) when reporting to PUS…
“We are unable to provide an assurance to PUS that (the above regulations are) operating efficiently in all Service PAO areas”. There followed 19 recommendations. Read them, then Haddon-Cave’s, and weep at the commonality.
My MoD(PE) 2 Star dismissed the report as “of no concern to MoD(PE)”.