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Old 14th May 2016, 13:57
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Engines
 
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Perhaps I could add a few comments that might be of some help.

The first is the use of the term 'pause', which was used in this case. Of course, it's a political tactic, but one that obscures the truth, which is never a good thing. This is a grounding. Or it could be called a 'cease flying' order. The reason? The ATC aircraft fleet is non-airworthy. It's non-airworthy (as far as we can tell in the absence of much information) because the RAF lost control of the material state of their aircraft, either via inadequate documentation of servicing and repairs, or inadequate documentation of modifications. Or some of both.

I had direct experience of 'cease flying' orders issued by the RAF, and in both cases they were inadequately staffed and missed the crucial element - a plan to get the aircraft airborne again. I know that the RAF were capable of issuing perfectly good technical orders - sadly, I was clearly unlucky. Having a recovery plan was a key lesson drilled into RN Air Engineers, and on the three occasions I was involved in aircraft being grounded, a recovery plan was set in place straight away. (I can only offer the observation that when you are on a ship a long way away from help, and you ground the aircraft, the Captain is EXTREMELY keen to know how and when you are going to get the aircraft fixed).

This has been a pure shambles, and I say that because I can't in all honesty see why it has taken so long to get a fleet of extremely simple and basically well designed aircraft back into the air. Grounding a whole fleet at multiple locations also points also towards a serious systemic failure within the accountable organisation. And, in my personal opinion, this is where some key points around the MAA arise.

The MAA says that it is an 'organisation responsible for the regulation, surveillance, inspection and assurance of the defence air operating and technical domains'. (my bolds).

Again just my personal view, but the main thrust of the Military Aviation Authority (incidentally, not the 'Airworthiness Authority' recommended by Haddon-Cave) to date seems to have been in the area of regulation. So, we've had a complete 'rewrite' of the books, but as Tuc and others (including the new DMAA) point out, this has really been a reissue of the old regs. (Unfortunately, in some areas, the sense of the old regs has been diluted or lost). We've also had a mighty edifice of authorisations and certifications erected, with Letters of Delegation (or whatever they are called this month) extending to tens of pages, and every single person associated with aircraft support being required to be certified as 'SQEP'. As well as the 'Duty Holder' system, which has had the effect of moving decision points at least two ranks upwards from where they were.

What's not as evident (to me) in the MAA's activities are surveillance, inspection and 'assurance'. What does the MAA think of a 'pause'? Did it support it? Or of a 'pause' that lasts well over two years? What about that? Or why an RAF owned servicing organisation got into such a state, despite the MAA's surveillance, inspection and assurance' regime? Why hasn't the MAA opened an inquiry into this debacle?

This is a common issue with other accidents. The MAA reveals that they couldn't find any documented records of an organisation's decision making process around an RTI that was directly linked to the death of a Red Arrows pilot, and then....silence. Where was the MAA mandated 'pause' for 22Gp's engineering management team? No safety case for an ejection seat - where was the MAA mandated 'pause' on the responsible PT? Assurance, anyone? Why does the MAA keep issuing SI recommendations that, as Tuc so excellent points out, amount to no more than 'comply with mandated regulations'? Why not do something about the organisations that didn't do their job?

Surveillance and inspection? I've worked in PTs that didn't carry out the most basic elements of airworthiness assurance. (Examples - proper control of airworthiness files, effective configuration control, management of modifications - I could go on). And these PTs sailed through MAA 'inspections'.

My final thought - I'd be a lot more comfortable about the MAA if it started withdrawing some of its approvals for organisations that have manifestly failed to operate correctly. Same goes for individuals. Let's see some Duty Holders relieved of their duties.

Sorry if I've gone on a bit here - it's just that I feel strongly about this stuff.

Best regards as ever to all those trying to do the right things,

Engines
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