PPRuNe Forums - View Single Post - Self Regulation Does Not Work, and in Aviation it Kills!
Old 29th Mar 2017, 20:32
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EAP86
 
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There's a lot of detail in previous postings so I hope you won't mind if I generalise a little in response.

Any aerospace regulatory system, military or civil, exists to assure fitness for flight which is a property of the platform. Almost all definitions of 'airworthiness' are concerned with safety (fitness for flight) and they recognise that airworthiness is a property of the platform. The only western nation I'm aware of which brings fitness for purpose into its definition of airworthiness is Italy. I am not trying to say that fitness for purpose is not important or operationally essential, it's just that airworthiness (using my definition) has to come first. I have no problem with any relevant area of expertise having a contribution into the determination of airworthiness and I certainly include aircrew in this.

I do however have reservations with the current MAA approach to RTS regulation in that it is over-complex, suffers from a fair degree of duplication and seeks to involve all parties that have ever been involved historically with the production of the RTS irrespective of their competence or usefulness of contribution. Too much of the RTS process is driven by the organisational topology of the MOD and Service Operating Branches. To be fair to the MAA, they probably appreciated they were compromising matters but it was deemed necessary to obtain the buy-in of VSOs. My comments about RTSAs were in the context of how the contribution is made, not in the principle of taking aircrew inputs into account.

Much as Nutloose charges, I do admire the EASA regulatory system (the CAA's is hardly worth a mention as it is barely used) in that it seeks to place decision making in the hands of those competent to do so. Note that EASA didn't make the mistake of taking all powers to itself, something upon which the MAA is also to be congratuated. Nutloose seems to have issues with the implementation of the EASA system but without knowing more about the particulars, its hard to comment. I will say that regulation is a thankless task at the best of times as shown by the old term for the CAA, the Campaign Against Aviation.

I'm aware that under the pre-MAA regulatory regime George Baber actually tried to sort out a regulatory approach modelled on the authority structure of the EASA approach, working from first principles but adapted to the needs of the MOD. As you might imagine, that work probably wasn't given too much attention by the MAA; a pity as it could well have avoided some of the complexities of the current system.

EAP
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