TCF
Excellent post.
One comment....
The ODH signs-off the "Risk to Life (RtL) Register" of all of the items on the Risk Register (an MAA requirement) and that, in this instance, he was not satisfied with the lack of authorised engineering support with respect to authorised repair schedules to the ACO aeroplanes.
While true, and mandated policy since God knows when, although terms have changed, what the MAA refuse to get to grips with is the formal rulings that a 2nd or even 3rd Risk Register may be created, excluding all MoD-owned risks (such as you describe), to be wheeled out come audit time or investigation. This occurred, for example, after a multiple fatality crash in 2003, which 3 weeks ago (19/1) was submitted to the Defence Select Committee by an MP representing the family of one airman. The MAA are fully aware of this, but won't talk to you about it. Matters aren't as clear cut as they would have you believe. I think they are well-intentioned, but lack of independence stifles them.