The MAA needs to go back to basics; air safety within the MoD was not invented by Haddon-Cave. Adequate regulations were in force long before that, they simply weren’t followed. Unfortunately, since his review the MAA has tried to reinvent the wheel and in many areas has come up with a square one. It still turns, but not as good as the previous round one.
Let’s revisit BP 1201 and the guidelines set out there. Where the risk matrix (probability against severity) is used to define whether a risk is intolerable, tolerable or broadly acceptable and not which level of Duty Holder holds the risk. Passing the risk to a higher level does not eliminate or mitigate the risk. On the subject of risk severity, why was it necessary to change the criteria for category levels so that, for example, Remote went from ‘Unlikely to occur during the operational life of a particular fleet’ to ‘Likely to occur one or more times in 10 years’; the latter being more in line with Occasional or Probable under BP 1201? Of course it did allow a Class A risk to become a Class B risk, overnight, and lowered the standards.
Let’s accept that safe means that a risk is broadly acceptable, or tolerable and ALARP, and by ALARP I mean the legal interpretation set out by HSE and not ALARP (temporal). According to the narrative verdict handed out at the Nimrod inquest ALARP is a current requirement, not a future one. That is why Andrew Walker called for the grounding of the Nimrod fleet, because the fuel system was not ALARP.
Having legally accountable Duty Holders, is a good outcome from H-C, but they need tighter guidelines to work with; remember most of them have only done the 2 day course. As it stands at present I believe that the TOLERABLE and ALARP standard set out by the MAA is so subjective that Duty Holders choose to state whether it is or isn't depending on how they feel. As yet not one of them has been held accountable after three major accidents.
DV
Last edited by Distant Voice; 17th Sep 2017 at 10:30.
Reason: spelling, addition