Originally Posted by
Engines
Leon,
Thanks for starting what will be a really interesting thread for discussion and opinion. Here’s my attempt to help things along. When we talk about ‘self-regulation’, perhaps it might help to try to define what activities we think an ‘airworthiness regulator’ should do, and who should (or should not) be doing it.
1. First one’s obvious – to be the authority for all regulations, covering both operating and technical airworthiness. I think a high level MoD department should be doing this. Next is the job of setting up and running systems for reporting occurrences and events that bear on airworthiness. That includes providing independent oversight of the outputs. Again, I don’t think that having a two star led MoD Centre organisation doing that is a bad thing
2. Now a contentious one – assurance. Who audits the operation of the system to make sure that people are doing what they’re supposed to be doing? Again, I think that a two star led MoD centre department should be sufficiently separate from the DE&S and the Operating Commands to do be able to do this. Note that this aspect doesn’t include the next one:
3. Accident Investigation. I think this is one Haddon-Cave got it wrong. Conducting inquiries into accidents should be taken out of the MAA’s control and moved to a separate Government Agency, possibly reporting directly to the Secretary of State for Defence. This would allow inquiries to properly examine whether the MAA’s actions had a bearing. The MAAIB should be moved to the same location, but reporting separately to the SofS.
4. I’ve kept the contentious one until last. Haddon-Cave was clear that the role of RTSA should not be carried out by Service Commanders. He devoted a lot of space to arguing that the new MAA ‘Operating Airworthiness’ department should carry out the RTSA role. I agree that RTSA should be taken away from Service Commands – it’s here that some of the most egregious airworthiness failings (and cover ups) have taken place, with wholly inadequate and plain incorrect documents being used to put unsafe aircraft into service. The MoK Chinook was an example.
5. However I(and here I’m probably going to upset the pilots) I think it should go to the Technical area of the MAA, not the ‘Operating’ area as Haddon-Cave recommended. Preparation of an RTS is, in my view (a stand by for incoming) a systems engineering task. It uses the evidence developed by the technical processes of procurement to develop a safe and auditable set of limitations inside which the aircraft can be operated. It’s inextricably linked to the configuration of the aircraft. It’s a technical document, and should be owned and authorised by a technically competent person. At that stage, aircrew can take it for use.
6. Which brings me to my last point. Why didn’t the RTSA role go to the MAA as Haddon-Cave recommended? As I remember, there was a gap of around two years before the RA (1021) on RTSA came out, which confirmed that the role remained with ACAS for the RAF, ACNS(Pol) for the RN and ACGS for the Army. My guess – the RAF VSOs decided that this was the ditch they were going to die in. Looking at the RA, having the RTSA role held by the Service command chain makes little or no sense. The RA actually says that the RTSA is supposed to provide ‘Independent Air Safety assurance’ – some hope.
This is a direct contravention of the MoD’s undertaking to implement Haddon-Cave ‘in full’, and should be corrected.
So, that’s my put – comments? Best Regards as ever to all those who want the system to be better,
Engines
As Leon initially said, the Defence Accident Investgation Branch does not report to the MAA, it is an independent organization under DG DSA that can report directly to the SofS via DG DSA. Item 3 on your list, check!