Eng
Sorry if I don’t answer your question directly, but I think the issue of training, and its undoubted link to airworthiness, is important, but the actual problem is organisational and failure or misunderstanding of process.
The regs (and mandated instructions to officers charged with implementing the regs) say the RTS is a pre-requisite to the commencement of aircrew training; and we already know the Safety Case (which must consider Human Factors as you say), FRCs, ACM and ODM are pre-requisites to the RTS. (Thus, they are all inextricably linked). However, I don’t think it should expressed as simply as this; I have managed many programmes where the training commences, and progresses incrementally, long before the RTS is issued. One has to be more flexible and “tailor” the introduction to service according to the nature of the programme.
Historically, as long as all were seen to be controlled by the same person (say, the Project Director), then I’d be satisfied. But then along came Integrated Logistic Support (v. 2.0, not the original concept ditched when AMSO was formed around 1990) and training came under the ILS Manager. This created two main problems. First, the ILSM was seldom part of the project team delivering airworthiness so control and oversight was lost – he was part of the Service HQ and increasingly untrained for the job. Secondly, ILSMs were (and probably remain) fixated on the “LS Date”, usually set in concrete at 3 months before In Service Date.
Any pilot can see the problem. If you deliver training at the LS Date, you only have 3 months to train sufficient aircrew and ground crew (and, for example, deck crew on ships etc). This seldom computes if the ISD is defined as “10 operational aircraft” and a pilot takes 6 months to train. I think Apache is a good example here. The training requirement is more likely to be scheduled properly, and integrated into the overall programme, if under the control of the programme manager who will understand the RTS may be issued, but it is of no practical use, without training. Thus, ACAS should not sign the RTS until he is satisfied it can be put to its intended use; rather like the obligation on me not to sign the Critical Design Review until satisfied it meets the spec (including safety). Again, the close dependency between airworthiness and training. In this sense, it is both, or none.
But to the problem here, lack of flying hours. That is an aviation safety matter. It is directly related to the Master Airworthiness Reference (RTS) as the RTS is based on a Safety Case which assumes a given level of currency and competence; in turn linked to the TNA and Training Plan. If that currency is lost, the Safety Case validity is compromised, and so too RTS.
The aircraft is but one part of a system (“a combination of physical components, procedures and human resources organised to achieve a function”). This last introduces the concept of functional safety. The aircraft may be physically safe, but the overall system is functionally unsafe if the operator is not trained. Therefore, to declare airworthiness, one must first train an aircrew to demonstrate functional safety in the system, and this process must then continue and be maintained through-life. Therefore, and this is where my views originate from, the RTS is a statement that the training plan has been verified, and a properly trained pilot can operate the system safely, within defined limits.
I believe in this case, if currency was lost or compromised, then the RTS should have been amended to impose limitations or restrictions on crews who were not current. This is where I have to stop as I don’t know what aircrew think of this, but it would seem from the discussion that the final manoeuvre was made “difficult” by a combination of the aircraft configuration and lack of currency. The former is quite definitely a fundamental component of the RTS so there is a clear overlap. To a Risk Manager, lack of currency is a risk (was it notified as such by Tornado bosses?). It would seem reasonable that mitigation would include restrictions until currency was achieved. It works the other way round when the RTS is first issued. One builds up to flying within the complete envelope through progressive issues of the RTS, as the aircraft and its behaviour are understood. I’d be interested in aircrew opinion.