JTO: "Where I am not comfortable with is the attitude of the MAA by which it pushes issues back onto the Duty Holder chain whilst washing their hands. They don't even appear to have a moral compass let alone a duty of care to ensure that issues are resolved at the earliest practical level." I believe they do this because the legal duty of care for safety is mainly owned by the operators, hence the "Duty Holder" term (as an aside I think the term actually causes far more confusion than its worth). The MAA have expended considerable efforts trying to ensure that the operators understand their obligations.
Engines, point 3. At the time there was general surprise that CHC made recommendations around accident investigation at all since it wasn't seen as a particularly problematic area. The management chain aspect was always going to be a contentious issue but pragmatically speaking, I don't think its been a real issue (apart from one DG's obsession with a/c scaring horses being ridden by the public, allegedly :-))
Engines, points about the RTSA. I think the MAA had a few difficulties with how to fit the RTSA role into their proposed scheme of things at all. If the RTSA had moved into the MAA, I think the role would have disappeared within a few years purely because the complexity of modern in-service types tends to interfere with the more technical aspects of the RTSA role. Nevertheless the MAA probably could envisage that technical deviations have become necessary in some operational contexts, so the possibility remains. I might not be explaining this very well but I'm trying to avoid an essay on the subject. Its worth noting that it is very much in the operators' interests to own their own safety assurance function since they hold the duties so the RTSA role isn't a regulatory dead end.
I believe that when the new arrangements were becoming clearer, the MAA did take CHC through the differences from his recommendations to assure he was comfortable with them. I believe he refused to adopt a more formal role as this would have been in conflict with the independence demanded of his role as a Judge.
EAP