New military aviation 'body' to set up.

[PPRuNe Pop]

BBC News - New military aviation body set up after Nimrod crash (http://news.bbc.co.uk/1/hi/scotland/north_east/8414698.stm)

Could this be another quango or is it a way of controlling events as they occur?

[Phil_R]

Wouldn't a staff of 250 give them enough people to assign one to every single aircraft in the UK military?

P

[cornish-stormrider]

I'm a thick sootie - are we talking about a MAA to control stuff like airworthiness?? and making sure things are done or does this look to be another job creation for graduates??

[Mick Smith]

MOD announces new Air Safety Authority


Defence Secretary Bob Ainsworth has today announced the creation of a new military airworthiness authority to ensure aviation safety standards are of the highest order at all times.

The Military Aviation Authority (MAA) has been created as part of the MOD's full response to the Nimrod Review by Charles Haddon-Cave QC following the deaths of 14 service personnel onboard Nimrod XV230 on 2 September 2006. The MAA will include an independent body to audit and scrutinize air safety activity. The MAA will be in place by 5 April 2010.

The creation of the MAA was one of two key strategic recommendations of Mr Haddon-Cave's report which have both been accepted by the MoD. The other key recommendation is a revised arrangement of safety responsibilities for those personnel charged with ensuring the safe operation of military aircraft.

Defence Secretary Bob Ainsworth said:

"My thoughts and condolences continue to be with the families of the 14 service personnel who tragically lost their lives in this incident. On behalf of the MOD and RAF I again apologise for the mistakes that were made. I also pay tribute to the Nimrod crews for their continual skill and professionalism. What we must do now is learn all the lessons from Mr Haddon-Cave's report and take all the actions necessary to implement them.

"I share Mr Haddon-Cave's view that we must ensure our future management of military air safety is of the highest order. I am grateful for the detailed proposals the Nimrod Review has made. We have examined these proposals thoroughly for the past seven weeks and we are already taking action to implement them, including the creation of the Military Aviation Authority to provide the leadership needed to deliver the highest safety standards. This is the most radical reform to MOD's airworthiness procedures since military aviation began. Mr Haddon-Cave's principles and his proposals regarding safety culture have a resonance beyond aviation and we are now looking at their applicability more widely across the MOD."

Air Marshal Kevin Leeson, Chief of Materiel (Air), said:

"The Ministry of Defence and the Royal Air Force is committed to learning from this tragic accident. Mr Haddon-Cave confirmed that the Nimrod aircraft remain safe to fly. He commended the findings of the RAF Board of Inquiry and the technical actions we had taken to restore integrity.

"In his recommendations, Mr Haddon-Cave proposed a number of improvements to safety processes that we had already made in our own immediate response to the crash, a number of which he recognises in his report. However, he goes further with the need for greater independence of regulation and audit from those who deliver aircraft day to day to operations. I believe these are sound recommendations and we already have a team working to bring the new Military Aviation Authority into effect."

[cornish-stormrider]

words of less than one syllabul please,

[Willum4a]

Cornish Stormrider,
I think he means going back to what we had in the 80's that worked. I'm just not sure where we lost it. :}

[1.3VStall]

The Chief of Materiel (Air) says "we already have a team working to bring the new Military Aviation Authority into effect."

Would this be a team from within the MoD, or an independent team capable of bringing fresh ideas and practices into play within an organisation that will, inter alia, perform independent audits on the MoD? I think we all know the answer to that!

[cornish-stormrider]

Thanks Willum, That giveth me a little more confidence, not much but a little.

[airsound]

Issued this evening 16 Dec 2009
STATEMENT
BY MR CHARLES HADDON-CAVE QC


“I welcome the statement by the Secretary of State for Defence, Rt Hon. Bob Ainsworth MP, in the Commons today regarding the MOD’s plans to implement the recommendations in my Report published on 28 October 2008.

“I welcome the acceptance by the Secretary of State and the MOD of the vast majority (80 out of 84) of my recommendations and, in particular, the creation of a new independent Military Airworthiness Authority under a 3-star officer, the setting up an entirely new Duty Holder structure, the implementation a new approach to Safety Cases, the establishment of a new Service Inquiry regime and Joint Service Military Air Accident Investigation Branch (MAAIB), the re-writing of the current Military Airworthiness document set, the appointment of a Chief Engineer to support each Aircraft Operating Authority, the addressing of personnel weaknesses in engineering skills, the re-examination of the MOD’s relationship with Industry as a whole, a new strategy for Acquisition Reform and the adoption of the new Principles which I have recommended.

“The Secretary of State told the Commons that, in all, the plan amounted to ‘the most radical reform to the MOD’s approach to airworthiness procedures since military aviation began’.

“In the final paragraph of my Report (paragraph 29.7) I said ‘The most fitting memorial to the loss of the crew of XV230 will be that the lessons from their sacrifice are truly learned, and the Recommendations which I have set out are fully implemented’.

“I pay tribute to the Secretary of State and the staff in the Armed Forces and MOD for the speed and thoroughness with which they have sought to address the numerous recommendations in my Report. I look forward to the full implementation of the plan.”

[Cows getting bigger]

Sorry, but I'm a little confused by the apparantly contradictory statements. Are we talking about the Military Aviation Authority (something that was bashed around about 5 years ago when I was a very lowly SO3 staff officer) where Airworthiness is one of the five(?) pillars are is this just going to be an Airworthiness Authority?

[Chugalug2]

CGB:
is this just going to be an Airworthiness Authority?
Only if we are very very lucky, CGB. Personally I won't be holding my breath based on the SoS's "Speech" which can be watched here in all its oratorial splendor:
BBC News - Military aviation body set up after fatal Nimrod crash (http://news.bbc.co.uk/1/hi/scotland/north_east/8414698.stm)
Trying to analyze what exactly is proposed is not made easier by the finger licking stumbling delivery with its idiosyncratic trailing off of emphasis and volume let alone placing emphasis within a phrase where you might not normally expect it. So what did he say? As usual more in ad-lib response to questions rather than in the prepared piece. Within that though is the curious explanation of what will make the independent Military Aviation Authority independent and of whom it will be independent. It will not it seems be independent of the SoS nor of the MOD which it will essentially be a part of. No, it will be independent of:
"Those who fly and maintain military aircraft".
Now given that this is the considered response to Mr Hadden-Cave QC's Nimrod Review, which as its name implies dealt principally with why XV230 crashed killing all 14 of its occupants, one might be forgiven for assuming the responsibility for that tragedy lay with "Those who fly and maintain military aircraft". However I seem to recall that he placed the blame fairly and squarely with the MOD's dysfunctional system of Airworthiness Enforcement which involves many very senior officers rather than those way down the food chain doing the flying and maintaining. So much for independence. The CAA is independent of all Civil Air Operators, this mongrel will not be independent but be a part of the Military Air Operator that Procures, Releases to Service and Supervises all UK Military Aircraft. Saying that it will mirror the CAA is rather like saying that Night Club Bouncers mirror the Police Service on account they both deal with drunks! If the MAA has any chance whatsoever in turning around the parlous state that the MOD has reduced UK Military Airworthiness to it will all be down to one man (or woman?) that commands it. That the position will be filled by a 3* is of some comfort. It would perhaps be of even more comfort if that person never subsequently gets made up to 4*!

[airsound]

Is anyone else getting strange filing times on this thread?

My last post shows as 0949, but was actually filed about 1749. Chugs shows as 1220, but actually filed around 2020.

I notice when I scroll down while writing here, the times are correct. but on the thread itself, 8 hours out. Wtf?

airsound

[PPRuNe Pop]

Its a PPRuNe thing. Been going wonky for some time now - sometimes it works sometimes it doesn't. :ugh::sad:

[Rigga]

To answer the question in Post 1
QUANGO!

This is a declared transfer of the old mentality into (presumably) a new building with an old Dept name on it.

The intent of H-C was to have a completely independant body consisting of non-military staff. This one is to be headed by a 3-star and is "already" populated by probably the same drongoes that caused the issue in the first place!

Given the size of the CAA in relation to the UK fleets of approx 1300 aircraft - this MAA has an assumed size of 250 before it even knows what it's going to do?

Smacks of a huge money-sucking QUANGO to me!

[1.3VStall]

Chugalug 2 and Rigga, I am with you.

Appointing a 3*, who will then recruit his cronies from within into key positions will not provide the independent Authority that H-C envisaged and that most of us see as an imperative.

The new Authority must have senior people who can bring fresh ideas and radical thinking to the new organisation. I can think of many people who were serving in the military (at all levels) when we had an effective and accountable airworthiness chain. They have since gone on to forge successful careers in the commercial aviation sector and thus experienced a different regulatory regime.

Surely we should be looking to these people transfer their skills and experience into a new MAA and not just looking to the MoD to reorganise itself from within?

[Bismark]

It will be filled with people from the very Service that H-C so heavily criticised - the RAF - so no change eh! Be bold - put RN, Army or civilian in charge for the first 3 - 5 years.

[flipster]

I am in total agreement that the independence of this new MAA needs to be absolutely uncompromised. But the fact that the MoD have undertaken to form a MAA at all is to be applauded. I truly expected the MoD to completely ignore the main recs of H-C. So, this is more than I would have expected. Nonetheless, all the MoD have done is to say that they will actually implement the already-mandated regulations contained in JSP553 (and all other related docs and Def Stans etc) but which had been ignored for some time by PE/DLO/DPA/DE&S. That, at least, is a blessing. But I can't really comment in full, as I have not yet found the complete Aintworth/MoD statement - anyone got a copy/link? eg What 4 H-C recs are the MoD not implementing?

flipster

[NUFC1892]

Oh look, another 3*, who would have thought :ugh:. Would an individual within the CAA not have been more appropriate and independant?

[raedwald]

Serving officers on the MAA will be subject to the pressures of patronage and promotion. I doubt that they will be able to be perceived as independent.

At the bottom end of the tree, the only people who are likely to be appointed will be the no-hopers. It would be the kiss of death to the careers of most of those below Gp Capt. So lots of people looking for a quiet life will not tend to make good things happen.

[Mandator]

NUFC1892 - if you think that the CAA is a repositry of airworthiness best practice, I fear you have not had much to do with them over the years.

[Cows getting bigger]

Isn't there a spare floor at Belgrano that could be used? Joined-up approach and all that.

[Chugalug2]

Mandator:
if you think that the CAA is a repositry of airworthiness best practice, I fear you have not had much to do with them over the years.
Apologies for butting in, to both you and NUFC, but the glaring difference between these two Airworthiness Authorities is that the one you speak of has not caused needless deaths by deliberately not enforcing its own Regulations. For any shortcomings that it may have the CAA would be a quantum leap in airworthiness provision if it presided over the Military Airfleet in the same way that it does the Civil one.

[Rigga]

I have dealt with the CAA with regard to airworthiness for many years and found them, more often than not, very fair and they've stuck to the rules (sometime too rigidly!) but they stuck to them.
Sometimes, you can even force the CAA to stick to their own rules too. Try that with the military Un-set Jelly/Knitted Fog systems!

[seafuryfan]

I wonder if the 3 star will have the final say on accident reports, like they have done up to now? I seem to recall in past reports that if they disagree with the
report they tell the board to look at it again.

Or will they have to back the findings of the independent panel of experts? Will these experts include civilians? Will the experts be trained to CAA accident invesigator standard? Or will the MAA be a tour in post for an individual, then to be posted somewhere else after 2-3- years?

[flipster]

Dear Mods

If deemed appropriate, could the mods merge this thread with the main Haddon-Cave thread?

BTW re MAA accident investiagtions - if there is a conflict of interests, the BOI Pres can report directly to the PUS and bypass the chain in toto - a improvement on the present.

[Chris Kebab]

Personally think this MAA thread should be kept separate from the H-C one.

A good start would be to ensure that this "3 star" is not a man in a uniform and ideally is recruited from somewhere external to the MoD who can arrive without the current RAF and/or MoD regulator baggage.

Simply promoting the next available 2 star RAF officer into the slot would be nothing short of ridiculous - however I suspect that is what will happen.

[Papa Whisky Alpha]

Regarding the second paragraph of your post -- I put this very point to the CAS on Wednesday the 16th of this month following the statement by Bob Ainsworth in the house. He assured me that they would be appointed for their professional qualifications and experience, that it would not be just another post in the career chain. I also pointed out that people who work in the CAA, AIB, etc do not have a professional development that requires them to "move on" just when they become competent in their current post.

[Safeware]

My concern is where are they going to get 250 people (accepting not all of them will be "hands on") who are suitably qualified, experienced, available, willing to move to those jobs???

sw

[acmech1954]

If the intentions are to shut a couple of squadrons, there is your 250 bodies required, no probs. Whether you wanted to be in a particular job or place has never bothered the MoD up till now, you went on a training course, became an expert and went to places you were told to go.:{
I do beleive that it should be higher % civilian though, with a mix at all levels, as stated before , they will not be looking at their career path and knowing that they will only be in post 2-3 years, it would also help to stop the new broom syndrome, especially the re-invent the wheel one.:ok:

[Blacksheep]

Way back in the olden days, while working in the instrument workshops we lived in fear of the AIB inspectors, civilian chaps who enforced airworthiness standards in RAF, FAA and AAC workshops. They were the military equivalent of CAA Surveyors. Of course they cost a lot of money and weren't productive, so they had to go in one of the never ending defence reviews. :rolleyes:

[Rigga]

I'm just wondering what these 250 people are going to do?

[Chris Kebab]

Well as I understand it from a recent brief I sat in all the current DARS guys will all move into it plus all the Abbey Wood airworthiness and Wyton maintenance sections, then there is all the defence airspace management community, plus the guys that regulate MoD contractor flying, etc. I gather there is also a move to get ACAS's RTS guys in there as well. That adds up to a lot of people. Not too sure how all this fits with the desire to shrink both the military and civil service.

[1.3VStall]

CK,

So how one earth is the new MAA to be independent if it merely comprises re-assigned, re-titled current staffs?

I believed that the whole thrust of the H-C recommendations is that that a new military airworthiness organisation should be set up as the MoD has patently proved itself incapapable of assuring continued airworthiness.

What is being proposed is looking more like just a reorganisation of current MoD resources under an existing 3* officer. Where will the fresh ideas come from? Why are they not looking to import experience from outside?

[Safeware]

1.3, what did you expect?

Where else would staff come from? It shouldn't be about their hstory, but about the future.

sw

[Chugalug2]

Ah, I wondered who'd spot that one first, Wilson!
It was the whole thrust of the recommendations made to Mr H-C that the new MAA be separated entirely from the MOD.
Whereas the whole thrust of the recommendations by Mr H-C are along the lines that it will be part of the MOD but Independent!
Explanations on a post-card please.
At least it will provide employment for the Sign Writers.

[vecvechookattack]

Whilst H-C would suggest that the MAA should be separate from the MOD the biggest issue is who would pay for it? If it were to be separate from the MOD then would it sit in the NHS budget? How about Social Services? Transport would fit better but would we (Servicemen) want the MAA working for the SofS for transport? Clearly not. It has to be working for the MOD and responsible to the SofS for Defence.

[Chris Kebab]

Agree Vec, and for that reason it will never ever be independent. Hence my earlier post suggesting that at the very least the new head should be a non military man recruited externally. A least it would be a (small) step in the right direction.

As to what they will (should) do, I think Blacksheep has partially answered that one.

[Squidlord]

MAA Head: AM Timo Anderson
Operating Safety Regulation Group: RA Simon Charlier
Technical Safety Regulation Group: AVM Charles Ness

[VinRouge]

Verve, how about the HEalth and Safety executive? Would sit perfectly there.

[Chris Kebab]

..looks like business as normal then, what a missed opportunity:(

[tucumseh]

Operating Safety Regulation Group
Technical Safety Regulation Group


Isn’t it interesting that these titles reflect what has been said on pprune for the last 4 years, but was largely ignored in the Haddon-Cave report? Physical and Functional Safety.

The fundamental problem is that, while achieving Physical safety is largely routine, the last FIVE Ministers for the Armed Forces (Caplin, Moonie, Ingram, Ainsworth and Rammell) have lent their support, in writing, to the various 2/3/4 Stars who have consistently ruled that Functional safety can be ignored. Not only that, but one can claim it has been achieved and pay off the contract, knowing that it has not. And it is acceptable to make a false declaration that it is safe. And, it is a disciplinary offence to refuse an order to make such a false declaration.

AVM Ness will know this, as he advised Haddon-Cave and (presumably) read the evidence. As Rammell confirmed his/MoD’s stance as recently as January, it doesn’t look like any senior staffs have dared seek clarification. Promotions to worry about? Ministers are, of course, simply briefed by the MoD Establishment. These officers will be seen as part of that Establishment unless they take a stance. Perhaps they are waiting to see who wins the election? The Tories been forewarned the question is coming – and so far their replies indicate a certain nervousness.

And then there is the question of regression work to plug the gaps in Airworthiness audit trails. It is now over 19 years since it became stated policy NOT to routinely maintain airworthiness. (Again, submitted to H-C). How many staffs remain in MoD who would know where to start with this task?

Carpet. Brush. Carry On.

[tucumseh]

Agreed its not that simple, but its the nearest MoD have come to discussing the differences since they were raised during the C130 and Nimrod cases. I found it strange H-C didn't seem to want to discuss the subject.

I really do hope they get this right but there is no escaping the fact that about 95% of H-C's recommendations could be covered by "Implement existing regulations". But there remain too many who have never had to do this because the regulations have been ignored for so long.

[4Greens]

It is a follow on from the Australian defence airworthiness model, set up to solve similar problems. Seems to work well.

[Rigga]

I've read the last few entries with interest - But I don't understand how you think the new MAA could move outside the MAOS regs? - unless they change them to water down their intent.

What's the likelihood of that? - After all, they do own them.

[Rigga]

I've been pondering this for a while now....

Surely, following H-C's review, contracted maintenance organisations will (if they're clever) now tighten their controls for fully auditable trails of (continued) airworthiness decisions and therefore insist on formally recorded reasons for the acceptance or rejection of (say) recommended or highly recommended modifications, reliability or maintenance programme findings.

Surely it is now going to be the contractor organisations who will drive the MOD's enforcement of their own (MOD/MAOS) regulation because that is all those organisations have to fall back on and is what their contract says they will follow?

What is the panels reponse to that? Could/can the MOD/IPT refuse to give recordable answers to their contractors?

[WeekendFlyer]

I have to say, I do not hold high hopes for the effectiveness of the MAA given that is remains within the MAA. The whole point of the setup in the world of civil aviation is that the safety regulator (FAA, EASA, CAA, etc) is completely independent of the manufacturers, maintainers and operators of the aircraft. Their only job is to enforce airworthiness and although they consult on maters such as costs, they are not hindered by them.

Now look at the typical MOD aircraft project team setup: currently they are very tight professionally and very busy providing support to operations, trying to manage contracts, spares and upgrade programmes, yet they are still allowed to decide what to do nor not to do regarding airwothiness of the platforms they are responsible for! Talk about being poacher and gamekeeper at the same time! Quite how the MAA is going to solve this conundrum is not clear to me, unless the platform airworthiness responsibility is taken away from the project teams and given the the MAA. But even then, what happens if the MAA says "thou shalt" and the project teams can't comply due to lack of funds? Would the MAA then say "ground your aircraft", or would there be a long protracted inter-departmental spat involving the usual elevation up through chains of command, delays, prevarication and maybe a decision eventually? At least in the civil world the CAA says "thou shalt" and the airlines and other operators have no choice but to comply or cease operating.

I just cannot see how the MAA will avoid conflicts of interest within the MOD. Sooner or later a major safety vs funding or safety vs operational pressures type of scenario will arise and I do not know if an organisation such as the MAA would be able to resolve it safely while staying within the MOD, unless the MOD heirarchy always let the MAA have the final word. What gaurantee is there that this would happen, particularly as the MOD funding situation is very likely to get even worse over the next few years? :uhoh:

Personally, I would rather see the MOD give a chunk of money to the CAA every year and have the MAA set up as a division within the CAA. At least that would lessen the potential for conflicts of interest, and it would also ensure the military community would benefit from civilian best practice where applicable. It should not go unnoticed that many of the major improvements in safety over the last few years have come from the civil side of aviation (e.g. Mode S and TCAS, GPWS, human factors, RNP RNAV, GPS RAIM FDE, etc).

Thoughts? Am I on my own in thinking like this? It would be interesting to hear some more opinions and debate.

Regards,

WF

[tucumseh]

Surely, following H-C's review, contracted maintenance organisations will (if they're clever) now tighten their controls for fully auditable trails of (continued) airworthiness decisions and therefore insist on formally recorded reasons for the acceptance or rejection of (say) recommended or highly recommended modifications, reliability or maintenance programme findings.In my experience, it is the contractors who have been pushing for MoD to implement their own airworthiness regs, but MoD have flatly refused. The inevitable outcome is that expertise, on both sides, has been lost. But, again, contractors are to the fore, rebuilding their "compliance" force in anticipation of MoD having to react positively to Haddon-Cave. MoD's complete disregard is best summed up by the demise of DGDQA.

One problem is that MoD, by selling off their 3rd Line workshops, long ago lost the natural in-house recruitment ground for people trained in the necessary disciplines. What does any 21 year old graduate know about Quality Assurance/Control, Configuration Management, Safety Management and the other 14 core components of maintaining a build standard (a pre-requisite to a valid Safety Case)? Nothing whatsoever I'm afraid, but any 3rd year apprentice at our old workshops has had it hammered into him. Who would you want to recruit to an aircraft project office? It is this aspect which lends credence to the argument to "privatise" MoD procurement. We simply don't have the capacity or capability any more and the choice is stark - thousands of expensive consultants or have contractors do it.

The cynical will say contractors would push (for more contracts), because it generates income; but it is not good for business for their products to be wrongly tarnished. I find most companies very concerned about this.

I accept there are exceptions. In MoD it is well known who the "protected species" are - those companies (and individuals) who can do no wrong and are awarded contracts no matter how poorly they always perform. I won't get into those mentioned by H-C, but will say this in anticipation of the usual "Wastelands" comments. Westland have always been, in my experience, superb. Their approach to this subject shames MoD.

[tucumseh]

WeekendFlyer

The independence you speak of (oversight, scrutiny etc) is mandated.

For the purposes of maintaining airworthiness, this independence was most visible in the HQ Mods Committees.

In 1992 the RAF (AMSO) decided to disband them. The first was disbanded in June.

A simple example, relevant to this forum. What did the Radio Mods Committee Chairman say when asked to sign up to the proposed FADEC software for Chinook HC Mk2, given Boscombe's confirmation it was "positively dangerous"? Oops, he'd lost his job the year before, so.... as you rightly say, poacher/gamekeeper. If there is one certain thing about that tragedy it is this; he would have deferred the decision (approval) until Boscombe were happy. No question.

[Chugalug2]

Weekendflyer:
Personally, I would rather see the MOD give a chunk of money to the CAA every year and have the MAA set up as a division within the CAA.
Would it were that simple, WEF. Everything you say in your post is certainly true, but the CAA can do little to help I fear. The UK Military Airworthiness Regulations are just that, particular and specific to our military aircraft. Civil Airworthiness Regulations have little to say in that respect, nor are those who impose them necessarily trained, experienced or qualified otherwise. Read what tuc has to say above and realise that there are now very few people like him who are similarly wholly knowledgeable about the MAR's. How the MAA, whether independent and separate of the MOD, or "independent" within the MOD, hopes to overcome that obstacle will be the first of many tests for it to be judged upon. I agree with you though that while it is constituted as the latter form it is difficult to see how it can perform its duties even if it wishes and is able to do so.

[colonel cluster]

Guys and Girls, i know its early days, but there is a huge amount of work going on, with Ind involvement, in how to look at airworthiness, both in terms of operating and maintaining capabilities. Perhaps supporting rather than bitching might be more appropriate. We are effectively starting with the civil regs, and looking at the particular needs of the service, rather than the usual deckchairs on the Titanic, making things fit current organisations.

Tuc, i have read your many posts with interest, be keen to understand how you would change things, yet still keep our fleets flying on ops? Oh, and by the way, blank cheques are not available!

Yours aye

El Colonel!

[Rigga]

Cluster,

Believe it or not, many people on this thread seem to be positive people to me. The fact that we are bothered to post our concerns about military airworthiness issues is, I believe, a very positive action.

However, if even I can figure out how to keep OOA Ops going and still work with some links to the current issues of MAOS regs (and at verrrry little cost - believe me, I'm good at keeping things cheap) - I've just got to ask what sort of people you are consulting with? Paid by the day perhaps? (joke)

Some of the remarks on here are whinges but many people are trying to be constructive.

The problem is that there is not much info available to be constructive about.

That H-Cs recommendations for independance is all but brushed aside has to breed some sort of remark and outwardly cannot be positive.

That H-Cs recommendations for experienced civilian management and staff is another "nail" everyone is remarking about.

Six months of H-Cs two year deadline to an independant audit also seems to have been quietly dismissed...

The information released to the public does not make logical sense in the public's view of Haddon-Cave and military airworthiness.

So!...about being positive...

[tucumseh]

El Colonel

I think you said it yourself. It seems there is much going on in MoD to work out what they are legally obliged to do anyway. It rather follows, I'm afraid, that if they have to ask they don't understand the question.

Far too many generations (and a generation in MoD terms is a 2 year tour) have been brought up to believe the things I talk about are a complete waste of money and are therefore used to the work not being done. That ethos has to change and, from what I hear, that isn't going to happen soon as the same lunatics are still running the asylum (with a few honourable exceptions).

As for money, I'm afraid there is no avoiding the need to resurrect and stabilise legacy build standards and, hence, Safety Cases; and then maintain them. Also, a need to recognise what I said about much of this not being volume related. If anyone in the MAA doesn't understand this in infinite detail by now, they are in the wrong job. And, of course, the regulations are largely common across Land and Sea, so those domains need an equivalent seeing to.

This, and more, was submitted to DPA's DCE (3 Star) in a paper dated January 2000, written as a direct consequence of the RAF's decision not to routinely maintain airworthiness and the resultant trashing by the Public Accounts Committee in 1999, and MoD's own Internal Audit in 1996. He didn't bother replying but I imagine his successor will have a copy somewhere. I still have mine. His (my) 2 Star did reply, but merely stated the Auditor's criticism was "of no concern to PE". Really? (Yes!). The only positive thing I can say about this hierarchy was they certainly practiced what they preached. H-C is the result.

Failing that, call forward the unpublished evidence submitted to H-C, which I know expanded on this paper. It is as good a starting point as any.

More than that, my rate is 50p an hour.

[themightyimp]

I find this thread rather interesting. There are very strong opinions (and rightly so) but little views on ways to solve the issues. Phrases like "functional safety" and "contractors" driving solutions are mentioned. Tell me who in the RAF has the functional safety competencies (qualified and experienced)? I can tell you. Two possibly three people and I can name them. I was one of them but had no chance to stay as an SME (with all that entails) and provide benefit to the Service so I left. Sounds like a whinge? Possibly. But now the military pays money to employ someone as a contractor whom they paid to develop but couldn't be bothered to try and retain.

Still, Happy Days. As long as we can learn lessons and make things better for those on the front line then all is well. Per Ardua! :ok:

[tucumseh]

imp

Two possibly three people and I can name them.

Quite right. Even fewer when it comes to maintaining build standards. One, that I know of, and he left Air Systems in about 93. He'd nothing to do as the funding had been chopped and the section disbanded.

You know there's a problem when retired staff are asked if they can update the Def Stans. I was even told that I would be put "on-call" and to provide contact details. It was the "free of charge" bit that made me laugh. 50p an hour. That's not too much to ask is it?

[Chugalug2]

Colonel Cluster:
We are effectively starting with the civil regs, and looking at the particular needs of the service, rather than the usual deckchairs on the Titanic, making things fit current organisations.
A word to the wise,CC. I strongly suggest that you start, continue, and stick with the MAR's. They are the one constant in this sea of storms. They have been derided, ignored, suborned and sabotaged in turn. All that "We" need to do is simply enforce them. You know, like they used to be by people who didn't use buzz words like; "No is not an option", or "There are no blank cheques", but who quietly and diligently did their job professionally, but so very quietly that young upstarts like me (well it was many many years ago!) scarcely knew that they existed. That is now a very challenging and demanding task, and you are right to imply that you will need all the help you can get. You will not get it from the MOD though, from which you need to be totally separate as Weekend Flyer rightly says. Not an option? Ah, therein lies the rub! Make it so as the good captain says, or whatever else is devised will be compromised from the start. Not bitching you understand, but "We" need to understand completely that safety doesn't come cheap, reinstating it is very expensive, but neglecting it is the most expensive option of all as we have all so sadly had to observe.

[Easy Street]

The appointment of an Air Marshal (and an ambitious one, at that) instead of an ACM makes me question how independent the MAA will ever be. Enforcing airworthiness regulations to the letter, and possibly thereby getting on the wrong side of CAS and CinC Air is hardly likely to smooth the way to the final promotion.... or is that too cynical of me?

[colonel cluster]

Folks, thanks for the comments, and I agree, its not an easy situation to fix. MAOS is one of the starting points, the EASA Regs even better. I agree there is not much in the public domain about what is being developed, but people are trying not to rush into developing and enforcing the regs without making sure they are the majority of the way there, otherwise there is a real danger that in the rush to show progress we give ourselves a set of regs that are contradictory and confusing. I think you will see the fruits of all the background work in the next year, as all the Services, and DE&S start to take the emergent policy and develop the teams to implement it.

Tuc, 50p/hr seems a great rate, look forward to seeing you taken on board.

El Colonel!

[tucumseh]

we give ourselves a set of regs that are contradictory and confusing.

A few years ago MoD considered updating one of the two key Def Stans on maintaining airworthiness (THE key one from my perspective, the one that every aircraft project manager should know by heart). This was both contradictory and confusing as it had been announced it was being cancelled, with no replacement (presumably because maintaining airworthiness was no longer routine, largely unfunded and branded a waste of money).

One of the conditions of the proposed contract was that the contractor would have to supply his own copy of the extant Def Stan, as MoD no longer had a complete one. (It is in 2 parts, separate books).

The contract was not let and MoD staff still cannot access over 50% of it (I've just checked the web site), but if you had airworthiness delegation prior to 1991 you may have retained your own copy. :ugh:

That procedural standard remains to this day the best source material for any project, not just aircraft. Use it as the basis for ANY project and you will seldom go wrong. Conversely, study the reasons for the procurement cock-ups (and various accidents, including C130, Nimrod) and you'll find that following that Def Stan would have prevented most.

But most of all you need people with the right background, experience and competence to implement these regs.

[Chugalug2]

CC, I see that looking back we have had a few exchanges before, all of an amicable nature of course, so I hope that the following can be seen in the same light. Do I understand that the "We" of which you speak are truly expecting to start with the BCAR's and then adapt them to the needs of "the service" (I'm not even sure which one that might be given that, as I believe, yours is of a wetter nature than mine)? As a certain tennis pro might say "You cannot be serious, man!". The MAR's were not derived in committees but evolved over the entire history of UK military aviation to ensure the airworthiness of our military aircraft. Now it seems you are bent on chucking the baby out with the bath-water simply because none of you possess the knowledge required to mind a baby! Find out! If the past few years of this benighted administration have taught us anything it is to beware of the Law of Unexpected Consequences. Adopting and Developing Airworthiness Regulations from scratch will be awash with such consequences. Don't, I earnestly beseech you, go there. The Regulations are not the problem. The problem is "We". It is "We" that has to change, not the Regs, and the place to start is in an Independent MAA entirely separated from the MOD, ideally "sistered" with the CAA but nonethe less enforcing the UK Military Airworthiness Regulations. Oh, one other thing, each of you needs to have a draft letter of resignation in "My Docs" and have the firm intention of submitting it if required. When push comes to shove that may well be the final measure of your bona fides.

[Rigga]

I believe that BCARs (if not withdrawn, then unamended since the millenium) are no longer a set of regulations suitable for use when either amending or refining any other set of airworthiness regulations.

No-one builds complex aircraft to BCARs anymore.

MARs have obviously been changed, over the last few years, to reflect the current regime/ethos for military airworthiness and budget optimisation practices, some of which could now be considered improper in some way or another. What to pick? what to leave?

I believe, as Colonel Cluster seems to indicate, that EASA (as recommended by H-C) appears to fit the bill for a current, working and proven system - even if it does have its faults and is not military enough. MAOS is the next step, but they too need re-writing to become a more coherant and useable model - perhaps including military versions of ALL the parts of EASA this time?. All MAOS Regs refer to Part 66 - where's that?

Lots of thought, lots of work and, no doubt, lots of meetings.

I agreee with Chugs sentiment that all was okay in the past, but it's often impossible to wind a clock back. You can change what the dial says, but not the gearing.

Other things have moved on too and 'we' are where we are now - having to let "youngsters" sort parts of this problem out without our help....for the time being.

The time will come when the MAA publishes its final issue - and then we will have our input - but likely too late to change some unconsidered condition.

That brings me onto the subject of "Notices of Proposed Rulemaking" (NPRM)...In my day, not too long ago, Rules were issued and changes made virtually overnight. This is impossible now the MOD has so many "partners". How can you expect civilian firms to change what they do - without notice.

Do the MOD notify concerned parties of proposed changes to regulations? Or do those parties just have to catch up when they can? Thus allowing utter confusion and many unexpected contract changes (again)

It seems to me that if the MOD included the contractors in the later stages of these regulatory musings, something workable for all parties may well evolve.

[Chugalug2]

Rigga, your reasonable informed response is in sharp contrast to my hot headed tirade at Colonel Cluster. I hope he will at least take into consideration that my ernest wish, as with us all, is to see UK military airworthiness working again. We should always bear in mind that the reason that it isn't working now is because of deliberate policy initiatives taken at the highest command levels over several decades and that many aircrew have died in accidents involving unairworthy aircraft in that time. I suspect that H-C was prevailed upon to arrive at the "Independent but within the MOD" model for the new MAA. What it does and where it goes is thus subject to the SoS for Defence. He, as with his predecessors, has seen fit to stand firm over the greatest airworthiness scandal of them all, the Chinook HC2 RTS leading to the Mull tragedy that cost 29 lives. Those responsible for that scandal are yet to be brought to account. By starting with a clean sweep of the Military Airworthiness Regulations the MAA will imply, if not openly state, that the old ones were wanting and thus allowed for previous unairworthiness. That would be a lie heaped upon all the other lies that lay scattered around this unseemly saga. Of course the Regs need updating, probably extensively. They always were, for it was ever a process of evolution. What it was not was one of revolution, and if that is to happen I for one will draw my own conclusions.

[Rigga]

Chug,
To bring in a new set of regulations to anywhere that has had traditional ways of working for many tens of years is a revolution.

To introduce these new regs into the Mindset of the MOD/RAF is going to take years of dogged education, indoctrination and persuasion to get people to first recognise what is written in front of them instead of what they want to read. Only then will they realise what they should be doing, and start doing it.

Luckily, some members of the RAF are williing to change, and learn new methods. I wonder how many will change their ways moving into the MAA?

I just hope that the temptation to do a gradual change is recognised as a folly. I wonder if the new regs will go ALL the way?

Time will tell, one way or the other.

[Chugalug2]

I think we need to cut to the quick here. Aviation does not tolerate a dependence on unjustified optimism or wishful thinking. Try it and you will be lucky not to die. Yet here we have the declared plan of not just the RAF but of all UK Military Aviation, in answer to the admitted failure of airworthiness provision, as the adoption of brand new regulations by the UK Military Airworthiness Authority. This after the scandal of the UK Military Airworthiness Authority (aka the Ministry of Defence) having a policy of not enforcing its own regulations over more than twenty years. In that time there have been the following accidents to aircraft that were unairworthy and/or unfit for purpose:
Chinook Mk2 Mull of Kintyre 29 killed
Hercules Iraq 10 killed
Nimrod Afghanistan 14 killed
To that total of 53 deaths could be added the 7 from 2 Sea Kings and 2 from a Tornado that also had airworthiness deficiencies, and likely others as well. Now those aircraft were not unairworthy because of poor regulations. They were unairworthy because the regulations were not enforced by the UK Military Airworthiness Authority (aka the MOD) as a matter of policy. Putting aside the fact that such policy would be a criminal act in itself, what possible confidence can one place in the MAA's proposal to resolve this scandal by adopting new regulations when the real problem is that it remains part of that same MOD? The reason that the CAA is independent of the airlines is so that it can do its job objectively, ie to enforce the UK Civil Airworthiness Regulations. The reason that the AAIB is independent of both is so that it can do its job, ie to investigate aircraft accidents. In Military Aviation all three, AOC holder, authority and investigator are one and the same, ie the MOD. When push comes to shove they will fail again, as they did before. We need a revolution I agree, though not in the regulations but in how they are enforced, which must be seperate and independent of the MOD. The MAA is and never will be that while it is part of the MOD no matter how much that is denied. It is a turkey as presently proposed. The same comments apply to the MAAIB, which may well have to criticise the MAA (as the Chinook BoI should have done of the UK Military Aviation Authority (aka the MOD) releasing the HC2 into military service) and yet is to be part of the MAA. In short the Emperor appears to be grossly improperly dressed!

[tucumseh]

Well said Chug.

My take on what is happening is that much hand wringing is going on worrying about re-writing the regulations but MoD may be losing sight of one simple fact – if the existing regulations had been followed the accidents you mentioned, demonstrably, would not have happened. It is a reasonable conclusion, therefore, that these regulations, while somewhat dated and perhaps a little cumbersome and hence costly to implement, are nonetheless robust. (But there is even a Def Stan which tells you how to minimise that effect while still maintaining airworthiness).

So, if they are to be tweaked, fine. I mentioned above that this need had been recognised many years ago (about 1993, certainly no later) but fell foul of the “waste of money” crowd – the non-technical beancounters who have the authority to over-rule engineering requirements and decisions (one of the first things an MAA must address). Even there, the regulations are crystal clear. “Engineering judgement” is paramount. Pity CDP announced in 1996 he didn’t need engineers.

But I think MoD has lost the plot. There are aircraft whose airworthiness must still be maintained. The lowest grade at which one can be granted airworthiness delegation has been raised, as least 2 grades, possibly 3. Many of those (relatively) senior staffs who now find themselves at the bottom of the airworthiness ladder instead of half way up have no experience whatsoever; in fact, many of that grade/rank are not engineers and so cannot be granted delegation. That doesn’t leave very many MoD staff to do the job and I suspect the “system” is frozen, awaiting guidance. Even fewer of that small band will have the slightest clue where to start. With a few exceptions, anyone recruited after about 1990 certainly won’t, because they will have spent their entire career being told “don’t bother doing that, waste of money”. Or DGAS2 & CDP’s 1998 classic (them again) – Functional safety can be ignored. God, I wish the resultant BoIs had been given this evidence; at least Nimrod and C130 would have been prevented. Proof, if any is needed, that rank doesn’t necessarily bring experience, competence, the ability to make a good decision or the balls to stand up and be counted.

[matkat]

As an aside to this in reference to the MoD/Contractor thing, several years ago i was working on the ASTOR project during my 1 1/2 years there 8 QA engineers were sacked (me included) all the sackings that I know of was because the said QA guy's brought safety issues to the table, the last guy that I know of that was sacked(GF) was about to publish an audit report stating that at that time Waddington was not in a fit state(Maintenance awarness) to accept the A/C when he notified the then QA manager of his findings and intentions it was subsequently discovered that he had some 'adult' pics on his computer this was also the way of getting rid of another 3 engineers (and I was also one of those).
Also 2 guy's sacked(DM & PC) for bringing a huge safety issue to management table in that there was an A/C being refuelled in the hangar with doors closed no fire cover no spill trays and the other 3 A/C also in there (the other was in greenville) subsequently when HSE became involved also Airbus(who owned the hangar) the 2 engineers were cleared of anything wrong and the tribunal subsequently queried why they were not there to give evidence on being advised why AB were none to pleased.

[Chugalug2]

matkat:
As an aside to this in reference to the MoD/Contractor thing...
It's not an aside at all matkat, but central to how a once proud Flight Safety system has been brought to its knees. I suspect that your story is typical of the experiences of many hundreds, maybe thousands of others. Whether they were directly persecuted for trying to act professionally or simply learned the lesson from such experiences of others, the net result was what was intended: that people stopped enforcing safety but gave lip service to it being complied with, or simply left out of despair and disgust. What was not foreseen by those who presided over this scandal is that forums like this would testify to such actions. What was also not foreseen was that an 800 year old institution, Her Majesty's Coroners, would give the lie to the MOD's assurances that its aircraft were airworthy and safe. The cat is out of the bag now. There is evidence available for this scandal to be properly investigated, whether it be within the military family or without. Time then that it was, for until the Armed Forces face up to it, no amount of sign-writing or new organisational charts will make it go away.

[tucumseh]

matkat

You describe perfectly the situation in London (92-96) and AbbeyWood (96-date).

Raising such issues is a disciplinary offence. The current Min(AF), Bill Rammell (Lab. Majority 99) confirmed he is content with this as recently as January this year.


A good QAR is worth his weight in gold. :ok:

[matkat]

Gentlemen, thank you both for your kind and encouraging words, I can not really add to what I have already written only to say that I think that my collegues and myself tried to do our utmost to uphold safety and airworthiness values and paid the price for it, I know that one of the people that I have gave initials for has read what I put down and concurs, I will try and get him to put this in writting here, also if I was ever approached in regards to my allegations I would be more than willing to back them up as i know that several of the aforementioned people would. The use of 'adult' pictures to discredit some of the fired personnel was something that became ridiculous as they were always found after an issue was discovered. Just as you know none of us had any recourse here as we were all contractors at Raytheon and the reason for dismissal was always that the affected person was surplus to requirements.
I have no problem in writting this because I know that the Airbus report would still be available and with the 2 subsequently dismissed engineers names on it vindicating their actions along with airbus concern over their immediate dismissals.
After the terminations several of the people(not me) discovered that they had had their SC clearance revoked due to this and found it extremly difficult to have new ones due to comments made by the sponsor.
Rigga, FYI it was Myself and one other that was involved in writting both the MAOS and the first Mil part 145.

[Rigga]

"QAR"? - I'm not familiar with that one.

Matkat,

Nice to contact someone who wrote the MAOS regs. I haven't seen the first ones so I don't know what that was like. From what you write I assume you didn't write 145 issue 2?

Whilst I can see they were written based on assumptions that other regs from "the Set" would follow (Mil Part 66 - still not issued), there are some large gaps in MAOS compared to EASA Regs and I've alway assumed these were due to cherry-picking instructions?

To counter the gaps in MAOS, some items were actually "left in" that I'd have thought would have been removed, such as the references to (CAAIPS CAP562 Lft 11-21) Safety Critical System Maintenance (I'll assume your already familiar with ETOPS configuration rules) that the average guy in the RAF won't have a clue about. Why wasn't this very specific paragraph removed? Did the Regulator think it meant Independant Checks? - If so, they were wildly wrong!

Using an F731 instead of a "MOD" Form One is another big loss - again, I assume there was the assumption from on high that the 731 could do the same thing (and I don't believe it does)

Did anyone in "industry" advise on the regs before issue? - Don't tell me a manufacturer did - what do they know of maintenance...

I would have to go through 145 again to get more questions on what drove some decisions to cut out some of the other pertinent articles.

I don't aim this at you personally - I'd just like to know what went on to get to that status. PM if you prefer.

Regards
Rigga

[tucumseh]

"QAR"? - I'm not familiar with that one.

The role of the MoD QAR on any project is crucial to attaining and maintaining airworthiness. His duties are listed in the various regulations. A project doesn't HAVE to have a QAR, but if it doesn't, the project manager must be suitably experienced to fulfill the role himself.

I think MoD got rid of them all by the mid-90s (at least on my projects) following various rulings that unnecessary regulations covering the likes of Critical Design Reviews, Configuration Audits, Safety Cases and the like can be completely ignored. Waste of money you see.

I understand what you're saying Rigga, but I think MoD would be wise to concentrate on the practical application of existing robust regs; especially those concerned with maintaining airworthiness. You can largely trust an aircraft manufacturer to deliver an airworthy aircraft but he, and his sub-contractors, will not maintain it unless MoD know what they are talking about and contract (and pay for) the right thing. They don't, despite it being mandated by the Secretary of State.

In all my years I never came across anyone at the various higher policy committees who understood that detail. Completely toppled if you asked them something basic, like what is the relationship between the a Functional Audit, the CDR and the Safety Case. It is that lack of understanding and the fact it permeated throughout the ranks because we stopped implementing the regs, that is at the root of MoD's current problems; not the regulations themselves. That is, for 20 years people have risen through that system who have no idea whatsoever how to maintain airworthiness. It became a career ending discipline. In fact, in 1991 one senior officer gathered his troops (whose sole job was maintaining airworthiness) in the St Giles Court cinema and announced they were the "rump end of MoD(PE)" because their knowledge and experience were no longer required. They were told to find other jobs, their section was being disbanded forthwith. An absolute dick of a man, but so typical of the ethos that remains to this day.

[matkat]

Guy's thanks for the PMs and I have replied. Rigga I did forget to mention in your PM reply that I am surprised that the MoD Form 1 was not implemented because it was certainly something that I had thought was done and accepted so obviously I have no idea why such a basic issue should be shelved the reasoning behind the proposed adoption of the form one was that the area of operations of the ASTOR would allow commercial spares to be used on it and in this respect it was engines that were of concern so it may well be by failing to adopt the form then they have again shot themselves in the foot.

[Chugalug2]

Rigga, as an ex-driver airframe I share the same ignorance of what you, tucumseh and matkat are discussing here with many others of my ilk. But then perhaps that gives me a better view of the woods that all the pretty trees that you are now planting will be part of. As tuc says, the problem is not the regs, it is their enforcement. That was grossly and deliberately compromised by diktat from the very top of the MOD. While the MAA is part of the same MOD then it cannot be independent, and just as importantly be seen to be independent, of such malevolence again. It is rather as though the Ministry of Transport (or whatever its name is this week) were found to have been the cause of numerous accidents and deaths due to a policy of saving money by switching off all the traffic lights and leaving potholes to just get bigger and bigger (OK, very far fetched that one I must admit!) and the solution proposed being a vast revision of the highway code to lower the accident rate. The solution is to force the MoT to do its job properly. The same goes for the MOD and can only be effected from outside it. Your pretty mansion is I'm afraid being built on quicksand.

[matkat]

Chuga, an interesting analogy and IMHO 100% correct.

[Jig Peter]

With all this reorganisation and associated discussions about improvements, I found the references to EASA leading me down a slightly different line, so apologies for any incipient thread drift.
The A400M, for instance, is set for initial certification under EASA rules, with military certification to follow - I gather this is a bit of a problem in itself.
How were programmes like Tornado and Typhoon managed from the certification angle? Did/does each participant's Defence Ministry do its own thing independently, or is there a system already set up to avoid duplication and time-wasting? (Not to mention imports from the US ...).
And, what systems are in force in various other European countries that the UK MoD might usefully apply to this new set-up they're organising?

( PS. I do realise that initial certification is one thing, more or less external to, for example the RAF, and that keeping the product properly "fit for purpose" is another, "internal" thing - the one leading on (ideally!) to the other).

[Rigga]

After a bit of Googling some time ago for "Military Airworthiness" I found the EU Defence Agency (EDA) (I didn't know it existed) who had already held an EU-wide Military Airworthiness Seminar to discuss the bringing together of said issue. The EDA calls it MAWA (Military AirWorthiness Authority) The UK was a key attendant state.

If the UK's plight is anything to go by, european unity in this matter may take some time.

Using the EASA model: If it took the original 12 willing states, and heavily driven by political pressures and multiple Type Certification costs, more than 10 years to develop and consent to a single regulation, just think how long a bunch of self-inflating military authorities will take to get to a single Title, let alone a whole regulation.

We can but live in hope.

Added Bit -

Forgot to mention that the Italians make a clear distinction between "Airworthiness" and "Mission Capability" that I don't think the UK military makes...

I also believe the UK military don't currently make the differences clear between "Airworthiness" and "Continued Airworthiness"?

Please correct me if I am wrong.

[tucumseh]

Forgot to mention that the Italians make a clear distinction between "Airworthiness" and "Mission Capability" that I don't think the UK military makes...

I also believe the UK military don't currently make the differences clear between "Airworthiness" and "Continued Airworthiness"?While we use different terminology, I think the broad equivalents would be Airworthiness and Fitness for Purpose; the regulations make clear the latter is an operational term. You may recall at the C130 inquest MoD couldn't field anyone who knew the difference, or could say who was responsible for the latter. (They could have, but I happen to know he was on leave that day). Briefly, the C130 was not fit for purpose because the MoD (not necessarily RAF) had not implemented the regulations properly (JSP553, plus Def Stan 00-970). The problem is that a cost cutting ethos has reduced achieving FFP to the same level as a savings measure - the ready acceptance of "Military Risk", thus pandering to the beancounters. But, in fact, to make an Airworthy aircraft FFP often costs much more, typically through the addition of Defensive Aids/Self Protection. The concept of it having to be first airworthy is lost on many.


JSP553 (Military Airworthiness Regulations) differentiates, in separate chapters, between attaining airworthiness and maintaining airworthiness. They are two entirely separate disciplines, carried out by different people in MoD. As I said earlier, the former need "only" be called up in the initial production contract and it will largely happen (as long as non-eng types keep their hands off and don't over-rule or waive legal requirements, which is one of the main problems MoD has). A simplification, but nevertheless valid.

Maintaining airworthiness is a far more hands-on discipline requiring many engineers with previous practical experience, not a piece of paper which says they've been to college for 3 years, but don't know one end of a spanner from the other. The job requires informed and accurate decision making on a daily basis, which is beyond most present-day MoD "project managers". It also requires strong leadership to fight this corner, because the beancounters see it as an intangible as the money doesn’t result in kit on the shelf. This is the part that MoD deliberately compromised from 1991, by chopping funding and getting rid of said experienced staffs. This is what most of the Haddon-Cave report is aimed at, although he doesn't spell it out like this; assuming, wrongly, that most in MoD will understand him.

[Chugalug2]

Rigga:
I also believe the UK military don't currently make the differences clear between "Airworthiness" and "Continued Airworthiness"?
I'm intrigued by your preoccupation with various European Regulations and their terminology, Rigga. I might simply reply "Words, dear boy, words!", but that would be both glib and rude, so I won't. What I would say is that the most important thing about Regulations, be they European, Italian or Serbo-Croat, is that they be properly enforced! Tuc makes the point far better than I, but I repeat that the challenge that the MAA faces is to enforce the UK Military Airworthiness Regulations, be they existing, amended, or brand spankingly glitteringly new. That requires experienced expertise that it glaringly lacks and complete independence of those that it will enforce them on which it patently hasn't. Failing that I cannot think of a more appropriate simile than the classic rearranging of the Titanic's Promenade Deck's Deck-Chairs to describe the present oh so British and oh so pointless exercise in futility. The MAA's job is not to produce reams and reams of bumf, it is to save lives. If it fails then more lives will be needlessly lost in avoidable accidents that are not avoided. Now these are grave and damning charges. Is there anyone who feels confident enough with the proposed MAA who is prepared to refute them? At least on the Mull thread we have our own in house group of MOD apologists/supporters who argue con, hopelessly in my book, but then I would say that wouldn't I? Here there is just silence; eerie, worrying, troubling, silence.....

[Chugalug2]

theprior:
However, it is the right thing to do.
Thank you for your post tp, whether or not it be in response to mine. The issue of course is what the "it" is to which you refer above. If it is the establishing of an MAA, then I am in full agreement with you. If it is the establishing of an MAA along the lines proposed by H-C, then there is where we go our separate ways I fear. You rightly say that there is a dearth of trained engineers over the last two decades and that is bad enough, but there must surely be a complete lack of them experienced in the proper enforcement of the UK Military Airworthiness Regulations as that has not happened for even longer. Given that was due to a deliberate policy of suborning the Regulations at the highest levels, military, civilian and political, within the MOD then the MAA provides no assurance that the same cannot happen again, no matter how good its head might be. It is not fair to him, to those who serve him, to those who will fly in the aircraft that he is responsible for, or even the wretched tax payer who has to pay for it all. The only way that the MAA can hope to work as intended is if it be sistered with the CAA, ie with those experienced in supervising a regulatory regime, and thus kept separate and independent of the MOD. I know there are many obstacles in the way of that, but it allows for the baby to grow unmolested by those who would otherwise harm it. This isn't only a job for those who know their stuff but for those who are determined to do their stuff come what may. If that "what" be senior to those within the MAA, then it needs to lie outside of such reach. With successive SoS's, let alone whole formations of Air Marshals, standing by the infamous Mull finding by Air Marshals Wratton and Day, such "what" goes to the very top of the MOD. Enforcement is the key here. It can only be guaranteed if the MAA lies without the MOD.
Let us hope at least that we can keep this tentative ball in play here. This site is for professional aviators, this forum for those of a military persuasion. If something as crucial as the proper enforcement of regulations providing for the very airworthiness of our aircraft does not involve everyone who claims to be a professional then the beancounters were right. Scrub the lot and hope for the best. Just don't offer to take me along for a ride!

[Rigga]

Chug & Tuc,

The reason for my 'preoccupation' with civil regs and terminlology is because in my 24 years in the Mob I never had to look for military airworthiness regulations or even to know what the APs (didn't have intranet computers then) were for those regs.

I, like very many of your groundcrew, only require the rules of how to complete paperwork and comply with instructions in the shape of APs, MODs, SIs, STIs, SEMs, etc. (Kept in the dark and fed on...) . IMO this lack of knowledge at the shop floor doesn't help the RAF at all.

However, I got my CAA Engineer Licences in 1989, while still in the RAF, but due to pension traps stayed in for quite some time, getting involved in local air ambulances, air shows and flying clubs, and even some visiting aircraft work, learning the CAA and JAA rules and regs as needed.

When I left the RAF, in was my CIVIL experiences and knowledge that helped me go straight into Civil Airline QA where I learned in great detail about Continued Airworthiness (CtAW).

I have been employed for more than 12 years conducting C of A's, imports, exports, new aircraft deliveries and even the odd disposal of unwanted aircraft, and involving a wide a variety of customers and airworthiness authorities, often using different terminology.

My 'preoccupation' is due to my lack of military airworthiness terminology and my need to attempt some translation.

I am sure we all strive to achieve the same things - its just that we all call those things different names.

P.S.

Totally agree with Chug on regulatory enforcement - at ALL levels. But, even in the RAF, trying to get the buy-in from protectionist user-unit managers will be a struggle!

[Chugalug2]

Rigga, as the one who used the word "preoccupation" in such an accusatory manner, my apologies. I had misread your interest in the MAA, wrongly supposing it to be more than simply academic. I hope you will understand that in being provocative I was merely trying to get a response from you as to the big problem, that being the enforcement of the regulations. This you have now confirmed and I thank you for that. If it is of any consolation, it is clear to me that your knowledge of such regulations, be they civilian or military, is far more extensive than mine. It is not only groundcrew that are not instructed in such matters, for I do not remember ever being taught about airworthiness as a pilot. Like you, my preoccupation (see, I have them as well!) was with serviceability. Even later as a Sqn FSO I processed MOR's not knowing that they reflected airworthiness problems for the most part, rather than mere serviceability ones. I quite agree that the MAA needs to ensure that the good word be fed to all concerned with aircraft operation from the very outset of training. Unfortunately we have all learned about airworthiness now for the very worst reason, its abandonment by the UK Military Airworthiness Authority (aka the MOD) and the terrible toll in lives that has caused.

[matkat]

In summary from Me, I think that at least Chug, Rigga and myself agree that at present there is no credible continued airworthiness management within the MoD (RAF) during my time on the ASTOR project it was glaringly obvious that the military(and the contractor) were only paying lip service to the idea of adopting a framework based around parts 66,145 & 147 it was in my opinion something that they felt was not necessary for them maybe brought about by the indoctrination of service personnel into thinking that they were superbly trained and had no need to change or be subject to civilian regulations which in all honesty would seem extremly alien to serving personnel. Both rigga and myself have been through both systems with a combined service engineering background of 37 years we see the flaws withing the system both military and civilian but the MoD needs a completely independent MAA headed by someone from civilian aviation it does not matter how good the ex AVM is because he never got to such a high rank by telling the brass 'how it is' If the military are serious about CAM then they have to go down the independent route however sadly it seems to me that the recommendations from H-C will not be implemented until we have another avoidable tragedy.

[Squidlord]

New MAA webpages:

Ministry of Defence | About Defence | What we do | Air Safety and Aviation | Military Aviation Authority | Military Aviation Authority (MAA) (http://www.mod.uk/DefenceInternet/AboutDefence/WhatWeDo/AirSafetyandAviation/MAA/MilitaryAviationAuthoritymaa.htm)

There's a lot of Nimrod, Chinook (Mull), etc. documentation at:

Ministry of Defence | About Defence | Corporate Publications | Air Safety and Aviation Publications | Flight Safety (http://www.mod.uk/DefenceInternet/AboutDefence/CorporatePublications/AirSafetyandAviationPublications/FlightSafety/)

Might have been there for ages though, for all I know.

[matkat]

Established 01 April 2010!! are they trying to say something?????

[tucumseh]

It has full oversight of all Defence aviation activity and, through independent audit, provides assurance to the Secretary of State for Defence that the highest standards of aviation safety and airworthiness are maintained in the conduct of military aviation.


Under the previous regime, successive SofS and PUS were consistently assured "through independent audit" that the same "highest" standards were NOT maintained.

They did nothing. The current incumbent was happy to confirm his stance in writing, supporting those who consistently ruled these standards were NOT to be attained or maintained.

So, assuming the MAA don't even bother asking him to over-rule himself (he's already refused), I do hope this is the first question of the new SofS after the election.

[Rigga]

With the labeling of Ops and Technical SRG's there is some early similarity to the UK CAA Structure - We will have a long wait to see if it follows that lead in any other ways.

Although I've heard of Charles Ness I don't know the others mentioned?

Lets hope that this new office will make the point that safety is cost effective, and drive it to being the norm rather than the exception.

In past cases the MOD has been really good at showing the first achievement of any new project and quietly dismissive at the lack of any other achievements after that.

I distinctly remember the mid-1970's dismissal of Time Promotion in favour of positive assessments stating that a JT could now get promoted in two years instead of three. Shortly afterwards the RAF news displayed a newly promoted JT with only 2 years in rank - a feat never to be repeated again.

Incidently, have you noticed that the single Part M approval gives the Tornado IPT the right of issueing ARC's!!!!
Can anyone tell me how that happens in a regulation that doesn't have that ability?

(Once a QA Man,...)

[Chugalug2]

Rigga:
Lets hope that this new office will make the point that safety is cost effective, and drive it to being the norm rather than the exception.
In that one plaintive plea I think you have put your finger on the nub of the MAA's dilemma, Rigga. They are condemned to a constant battle of justifying what they do and why they do it to the rest of the MOD. If the CAA was a joint stock subsidiary of the British Civil Airlines, and coincidently itself contained the AAIB, I imagine they would be condemned to the same fate and thus be a mere cypher, paying lip service to safety rather than mercilessly enforcing it. No matter how trendy their logo, how remote their HQ from Main Building, I cannot see how we may expect anything more of this latest example of the British disease of Self Regulation than with the others. The wheel has already been invented; ie operating, enforcement and investigation must be separate and independent of each other or people die. That is the stark truth of the matter and no amount of fudge can alter that.

[Squidlord]

Over the last six months, the MAA have started to produce Regulatory Notices (guidance) and Regulatory Instructions (mandatory instructions) concerned with aircraft safety. As far as I can tell, these are not publicly available (I can't find them at the MAA bit of the mod.uk website).

Not too much earth-shattering stuff (imo) until the RI concerned with aviation risk management came out about a month ago.

MAA RI/02/11 (DG) – AIR SAFETY: RISK MANAGEMENT

In the first instance, and somewhat in accordance with Haddon-Cave's recommendation that aviation (safety) risk management should be driven by the operators rather than the Project Teams, this RI is targetted at operators. However, if operators implement risk management in accordance with the RI, it's easy to predict that they will want PTs to manage risk in a similar manner. So it will impact PTs and, via the PTs, industry.

Anyway, the RI represents quite a departure from the traditional aviation risk management currently practiced by the PTs and I have concerns over how things will be migrated (it's one thing to say, "we want you to do things very differently" ... it's a lot more helpful to say, "we want you to do things very differently and here's some guidance on how you can efficiently achieve the change").

Furthermore, the new RI is rather incoherent and, as far as I'm aware, the new methods and processes its mandates have not been tried in anger. Basically, I worry we'll find it won't work!

I should add, the major changes embodied in the RI are concerned with how risk is measured (including a very new style of risk matrix) and recorded (a "risk register" concept similar to but different from the traditional Hazard Log).

[tucumseh]

Squidlord

I share your concern.

The point made throughout the late 80s (from 13th January 1988), 90s and 00s was that the mandated Safety / Risk Management processes and procedures were really quite robust (albeit dated); it was just that senior staffs in AMSO / MoD(PE) / DPA / DLO ruled the basic concept (maintaining safety) was a waste of money - and slashed funding. Especially AMSO in 1990-93; funding that was never resurrected. (Which is largely why the regs are dated - there was no funding to update them). It followed that very few staffs were actually taught how to do the job properly in that time. That doesn't make them incompetent, merely insufficiently trained for their task.

Haddon-Cave merely reiterated this fact, although inexplicably claiming the problems only started in 1998. (He has the correspondence proving 13.1.88).

Given those who ignored (e.g. DGSM, DGAS2 and CDP) directives successfully attained/maintained safety by simply implementing the regulations, I find it very odd the MAA have not once sought to learn from these successes. The only explanation I can think of is they don't want to upset certain senior staffs by being seen to contradict them - better to re-invent the wheel and risk making mistakes; which, from what you say, seems likely.


They really do have to learn that Chinook, C130, Nimrod etc occurred because mandated regs were not implemented, not because the regs were wrong.

[blagger]

tucumseh - you obviously have a particular personal beef with an incident(s) in your career that you use to underpin all your commentary / arguments. Can you please expand on the details of it?

[tucumseh]

Blagger

Not a single incident, by any means; and not just me.


In 1988 our entire Directorate in MoD(PE) complained about new policies issued by AMSO which effectively relegated safety and airworthiness to the back burner, by slashing funding. Prior to this, in my experience, the subject had been adequately funded, with errors caused by relatively rare failures to implement regs.

But, as soon as you deny funding, the problem becomes systemic - as reported to Haddon-Cave and accepted by him. It also becomes policy, in the sense that without funding a policy is only an aspiration. If there is no funding, then no work is being done and competencies/skills are lost. (Same principle others are applying to the MPA question). Regulations become meaningless and no-one thinks to update them. This is what happened progressively throughout the 90s.

The formal notifications of systemic failings continued until late 1992, when AMSO's Director General Support Management got fed up and threatened civilian staffs (those with airworthiness/technical/financial delegation) with dismissal if they persisted. His threat became largely academic - the lack of funding meant there was little to do, posts were cut and staff sought other jobs.

However, to counter this threat, Director Procurement Policy (DPP) was engaged and an internal audit initiated. Director Internal Audit (DIA) reported direct to PUS (Chief Accounting Officer) in 1996, fully supporting all the previous formal representations and making 17 recommendations. Not one of them was implemented despite all being directly related to safety and financial probity. The Nimrod/Chinook 2 Star in PE dismissed the report as "Of no concern to PE", which may help explain subsequent events on certain programmes. Obviously, PUS was similarly advised. Ironically, if you read Bernard Gray's report (the new CDM) he makes similar recommendations; as did Haddon-Cave. Both reports can be summed up with "Implement your regulations".


This 1996 DIA report removed the threat of dismissal for a while, but in 1998 the Chief of Defence Procurement made the same ruling as DGSM did in 1992 - it was disciplinary offence to implement mandated regulations, but dismissal was replaced with formal warnings. This remained the situation as of a year ago, supported in writing by the last four Labour Ministers for the Armed Forces (Caplin, Moonie, Ingram, Ainsworth). Clearly, not all staffs who tried to implement the regs found themselves under such threat - you have to have a particularly idiotic boss to have such a complaint levelled at you. Nevertheless, if it happens, you haven't a leg to stand on. The resolve of the new regime has yet to be tested, but first impressions are promising.


The above explains, I think, the underlying problems that have resulted in numerous deaths and the formation of the MAA.

You may not like what I say, but it demonstrably correct. MoD are quite happy to confirm the above in writing and under FoI, arguing their case strongly when defending their actions. It is only the advent of the Haddon-Cave report (which, as I said, is merely a collation of previous reports, applied to Nimrod) that has brought about a degree of change. What I think everyone must understand, in particular the MAA, is that not a single word of his report came as a surprise to anyone charged with managing airworthiness since 1988.

Don't shoot the messenger! Ask why so few spoke out. I have been entirely consistent with what I've said since joining pprune 8 years ago - all tragically borne out by subsequent events.

[blagger]

Interesting - not throwing stones, was just keen to understand the perspective.

[tucumseh]

Blagger


Thanks. Not just "interesting". Criminal I'd say. Haddon-Cave named the wrong people.

[Chugalug2]

Your "End of Military Airworthiness" saga above should be required reading for all tuc; aircrew, groundcrew, suppliers, administrators, in fact everyone from the CAS downwards. This is what lies behind every airworthiness related fatal military air accident, whether covered by a PPRuNe thread or no. 62 people have perished in such accidents at least and if that death toll is to be prevented from increasing inexorably something urgent has to be done. To date nothing urgent has been done despite the reviews and reports that tuc mentions. Now we await Lord Philip to present the next one. Unless and until the MAA and the MAAIB are independent of each other and of the MOD I see little prospect of any great change to this scandalous situation, created as tuc says of criminal neglect and the issuing of illegal orders. People have died, whole fleets scrapped and an abundance of treasure wasted. There is no redeeming aspect to all this unless you count the sinecure jobs, awards and promotions handed out to members of the Senior Officer Cadre. I rather suspect that is exactly what they did.

[Safeware]

Squidlord,
"Furthermore, the new RI is rather incoherent"

I'll second that. Says one thing one place, then another somewhere else - stuff will fall between the cracks.

sw

[Rigga]

I have just checked (or - phoned two mates) and, as far as I can ascertain, not one of the contracted Continued Airworthiness Management companies has any knowledge of any "RN" or "RI" in circulation.

It seems that airworthiness does not, in military terms, extend to continued airworthiness "partnerships"?

[themightyimp]

One could postulate that if you are in an ivory tower and throw things then you must be right...................

Of course the JSP55X series is being re-written, Def Stan 00-56 Issue 5 is being discussed and Def Stan 00-970 was reissued last year. All discuss similar things and say differing things in certain areas. Add RI's and everything else going on it makes a right mountain of paperwork. That's the great thing about standards there are so many of them :ugh:

Of course the question I ask is that in concentrating on processes and procedures they may increase the overall baseline and bring everyone to a minimum standard (hooray!) but how many of these processes and procedures actually reduce risk? Additionally, how many of them focus on health & safety law as that is what you will get prosecuted under.......

[Just This Once...]

I could fill several pages with my concerns over these RI's/RN's and the huge gaps appearing between the PTs and the new DDH/ODH structures. Glad we have plenty staff & experience levels on the 'operator' side to deal with these rapid changes and robust funding lines to seek external or independent advice...:{

If the PTs really did have all the provenance they claimed to support their existing Safety Cases or Hazard Logs it may have been a little easier...:eek:

Now that the operator community has started to flip over these troublesome stones we could do with an RI that instructed us on what to do when you find monsters scurrying around underneath that some PTs had managed to gloss over many moons ago.

What a mess.

[tucumseh]

Recent posts.... I agree with what you're saying, but would gently remind you of what I've said before. When criticising PTs for not doing the work (i.e. maintaining an audit trail), not all did this deliberately or knowingly.

Please remember that the necessary funding was withheld, posts chopped and the Corporate Knowledge flushed down the toilet. THAT is where the deliberate and knowing acts took place. Under those circumstances, it doesn't take very long for these basics to be consigned to distant memory with only a few dinosaurs left to bang their heads against walls and face the consequences when they try to implement the regulations.

It is all very well re-issuing these standards, but (a) is materiel and financial provision being successfully made to fund implementation and (b) staff being trained to do so (given both have been deemed a waste of time for over 2 decades). Who will train the staff? Who will train the trainers? Who knows how to make proper M&F Provision and staff it through to successful conclusion? MoD no longer employs these junior grades and the regulations rather assume the most junior in DE&S have already done all this before being promoted. Not any more!

[davejb]

A point that has been made on other threads for other reasons, but the basic logic of it is the same -

There is some incredible fallacy, I can describe it in no other way, that says the intent to resurrect or develop a capability is all you need to achieve it. Without the depth of knowledge spread across all levels of a subject - in other words 'when you want to do something and realise you sacked everyone who knew anything about it' - it takes decades to rebuild competency in any but the most simple skills.

Having effectively pruned airworthiness out of the defence business, not only do those at the top not know how to go about resurrecting airworthiness, but nobody lower donw the pyramid is really sure how to do it either. No matter how much determination the MAA now show, the sad inevitability is that it will take years for the MAA to become proficient.

I really think that those who castrated the existing process should be jailed (either for wantonly, brazenly, deliberately screwing it up in exchange for personal advancement, or simply for being thick...my own preference).

That so many such people go on to enjoy highly paid consultancies (while their mates and underlings remain in office, so the contracts can be awarded to the 'right' people) while the rest of us mere mortals live with the consequences, is nothing short of corruption.

Dave

[Chugalug2]

davejb, I agree with your condemnation of those who conspired to bring UK Military Airworthiness to its knees, and of course they should face the consequences of their actions. Ordering a subordinate to suborn the regulations is in itself an offence under Military Law, ie the issuing of an illegal order which should not only be disobeyed but also reported. When a superior to whom the offence is reported then chooses to discipline the complainant and support the perpetrator they in turn commit an offence, and so the cycle goes on, generating sufficient material to fuel enough Courts Martial to match any series of show trials of the 1930's. Personally I won't be holding my breath, preferring rather to get airworthiness restored to UK Military Aircraft ASAP.

You rightly point out that when such vandalism is committed it takes far longer to fix than it does to destroy. It needs someone with the drive and far sightedness of a Trenchard to see to it that the fixing is as quick and effective as possible. As those supposedly already charged with achieving airworthiness do not have the knowledge or experience required he will have to look elsewhere to find those who do. This is a challenge that has to be met. It will cost money as tuc rightly says, it will cost pride, it will cost reputations, it will cost careers, but if it is not done it will cost still more lives.

We need to remember that this happened not because the Regulations were deficient. They were not. This happened not because those who implemented them were deficient. They were not. This happened because senior Air Rank Officers ordered it so and under the present arrangements could do so again, no matter what the MAA assures us to the contrary. Only by removing that organisation from the MOD can it be provided with the independence that is its sine qua non. The same goes for the MAAIB. The AAIB is not separate from the CAA because of some quirk of fate but because it must be independent of Regulator and Operator so that it can lay blame on either or both if necessary.

My own preference would be to have each military regulator and investigator sistered with its civilian counterpart, but the nuts and bolts of the how's are best left to those who have to make this happen. The why's should be blindingly clear, to avoid avoidable airworthiness related fatal accidents in future.

[Rigga]

"...As those supposedly already charged with achieving airworthiness do not have the knowledge or experience required he will have to look elsewhere to find those who do...."

A few consultants milling around with the MAA, and doing the odd field trip, won't be enough!

A few 'recently-shown-something-to-do-with-this-stuff' "SME's" appointed into the MAA are woefully inadequate too, whatever erstwhile badge of office they wear.

They will, no doubt, be gone in two years anyway, and their regulations left UN-ENFORCED for open interpretation by OCs Eng, Squadrons, Flights, Hangars and Bays all doing their own separate and historically independant versions of what they consider is meant by the badly explained and implemented regulation they've been told to meet.

There needs to be some EXPERT guidance and mentoring for military engineers, technicians and mechanics at their place of work.

There still needs to be some REGULATORS that actually can REGULATE!

[Chugalug2]

Rigga, I absolutely agree with you. Airworthiness provision can only be done by dedicated professionals. We used to have them once. Somehow we have to get them back again. When you say:
There still needs to be some REGULATORS that actually can REGULATE!
you say it all, because they can only do so if they know what they are doing and have the unfettered power to do so unhindered. On that basis the MAA as is fails on both counts. The only people doing so at the moment are civilian regulators working for the CAA. Different regulations and different operators, but the culture is the same. Somehow that culture has to be grafted onto the military system and allowed to thrive. It can only do so if the CAA and MAA are two sides of the same coin IMHO. Ditto for the AAIB and MAAIB. Difficult? Sure! Insurmountable obstacles? Maybe, but they have to be surmounted nonetheless. An upstart fledgling service faced a similar challenge in 1918 and succeeded. Or is all that beyond us today? If so more die. It's as simple as that!

[dervish]

I'm the last person to claim any expertise on the subject, but I find all this talk of wheel reinventing and consultants with low level training absolutely frightening on such a subject. Does MoD not have it's own subject matter experts?


It is self-evident where the original detailed evidence to Coroners and Haddon-Cave came from and that the source knew exactly how airworthiness should be implemented and where the system had gone wrong. There was a short-lived link on the Mull of Kintyre thread to a submission to Haddon-Cave. The author clearly knew his stuff. Please tell me he, and those like him, have senior posts in the MAA. If not, why not?


Is it as simple as drafting in all aircraft related IPT Leaders into the MAA? Surely they are required to have this competence? If not, why not?


What of those who previously held delegation? Have they been suddenly deemed incompetent? What are they doing now?


I think these questions reveal a fundamental problem in MoD. Far too many senior post holders who have got where they are without gaining any practical experience at all. Can MoD still afford such luxuries?

[Safeware]

dervish,
"Is it as simple as drafting in all aircraft related IPT Leaders into the MAA? Surely they are required to have this competence?"

That's just sooo ridiculous it's almost funny...... if it wasn't such a serious topic. And those with previous delegations weren't necessarily competent either.

sw

[Rigga]

"I'm the last person to claim any expertise on the subject, but I find all this talk of wheel reinventing and consultants with low level training absolutely frightening on such a subject. Does MoD not have it's own subject matter experts?

Dervish,

The consultants are good and proper experts in civil regulations for Airworthiness AND Continued Airworthiness (the difference is quite defined)

The so-called "SME's" in MOD are the ones who've only just had recent visibility of what's required!

[dervish]

Safeware & Rigga

Thank you. It was just that the phrase

A few consultants milling around with the MAA

didn't engender confidence!


I'm glad to hear the consultants seem competent but my point is that surely the MoD, if they have have had and are to retain control over the subject, should surely have a modicum of pre-existing expertise. I mentioned that it was fairly obvious a couple of posters on here knew what they are talking about but is that it? Is the sum of all MoD expertise embodied in a few pprune posters? It would seem so and that this is indeed the place to come to glean future MoD policy and practice. Does he CAA or FAA conduct business in the same way?


And what the hell is wrong with a system that permits aircraft team leaders to know little or nothing about basic aviation matters? I'm sorry, but perhaps Gray has got it right. Farm the lot out to Industry. They can't do any worse as it seems we employ a vast army not to deliver something the likes of Westland would regard as routine.

[tucumseh]

Dervish. Well said.

I think the answer to your main point is that, no, MoD does NOT have the necessary in-house competence in the correct numbers. As you say, some of us have clearly been taught properly, but you have to be of a certain age as airworthiness funding was systematically targetted from 1988.

And the answer to your question about team leaders is No, they have not been required to know anything about aircraft during the same period, although to be fair there are one or two.

But knowing about how an aircraft works is not the same as knowing how to implement JSP553, in particular Ch 5 (maintaining airworthiness). That requires much more detailed training - which is a big stumbling block in itself. Your typical "boss" in MoD, be it Service or Civilian, is taught to ignore the detail; in fact, to denigrate those who understand it. When I look at the MAA staff list and all the gold braid, I just know what their reaction will be if you talk about a little detail. They'll topple, then shout and ignore you.

That was the reaction of their predecessors, in particular the 2 and 4 Stars who ignored direct written and verbal warnings which were, many years later, simply repeated by Haddon-Cave. They would all be wise to remember that. And the MAA is studiously ignoring those who gave those warnings, while desperately trying to avoid upsetting those who ignored them.

[Squidlord]

tucumseh writes:

They really do have to learn that Chinook, C130, Nimrod etc occurred because mandated regs were not implemented, not because the regs were wrong.

I think this is a very good point and it begs the question; why have the MAA seen fit to issue a regulation that moves the goalposts so much? (See below for my guess, which is different to tucumseh's.) However, I agree with themightyimp:

Of course the JSP55X series is being re-written, Def Stan 00-56 Issue 5 is being discussed and Def Stan 00-970 was reissued last year. All discuss similar things and say differing things in certain areas. Add RI's and everything else going on it makes a right mountain of paperwork. That's the great thing about standards there are so many of them :ugh:

I think the plethora of MoD standards, regulations, etc. connected with safety management could do with a good shakeout to reduce the total and make them more consistent. But that doesn't contradict tucumseh's point above - I'm not suggesting fundamental changes to the regulation set, just a shakeout.


My theory as to why the MAA have issued this RI, which seems to move the goalposts so much, is that they are only too aware of what Just This Once... writes:

I could fill several pages with my concerns over these RI's/RN's and the huge gaps appearing between the PTs and the new DDH/ODH structures. Glad we have plenty staff & experience levels on the 'operator' side to deal with these rapid changes and robust funding lines to seek external or independent advice...:{

I.e., the MAA is only too aware that the operators do not have the resources or expertise to properly address safety in the traditional JSP 553, Def Stan 00-56, POSMS way (which is certainly consistent with my limited dealings with operators). So the MAA thought they'd better mandate something rather simpler than the tradition.

I would have hoped that if they wanted to be seen to be taking military aviation safety seriously, the MoD would have considered investing heavily to provide the operators with the expertise and resource they are missing. But even if that were not possible, I would hope that the MAA would only consider such new, goalpost-moving regulation having first established two things:

a. it can work
b. either it can integrate reasonably seamlessly with the traditional safety management methods used by the PTs and industry, or guidance will be provided to the PTs and industry to help them change what they're doing to fit in with the new regulation.

I see no evidence of either, or even evidence that they have been considered at all!

[Rigga]

Squidlord said:
"I.e., the MAA is only too aware that the operators do not have the resources or expertise to properly address safety in the traditional JSP 553, Def Stan 00-56, POSMS way (which is certainly consistent with my limited dealings with operators). So the MAA thought they'd better mandate something rather simpler than the tradition.

I would have hoped that if they wanted to be seen to be taking military aviation safety seriously, the MoD would have considered investing heavily to provide the operators with the expertise and resource they are missing. But even if that were not possible, I would hope that the MAA would only consider such new, goalpost-moving regulation having first established two things:

a. it can work

b. either it can integrate reasonably seamlessly with the traditional safety management methods used by the PTs and industry, or guidance will be provided to the PTs and industry to help them change what they're doing to fit in with the new regulation.

I see no evidence of either, or even evidence that they have been considered at all! "


It is very difficult, and often impossible, to transfer an old aircraft design to new regulations or standards, whether the aircraft is civil or military. For this reason it should be quite reasonable to split some standards that have to remain with an older type, from the regulations and standards pertaining to a newer type. This would inevitably increase the number of regulations and standards in a single authority.

In civvy-street it is a common practice to keep a full set of the build regulations, standards and even drawings pertaining to one aircraft if new regulations have overtaken it. Doing this preserves and confirms the original standards of compliance. An example of this can be seen in the CAAs MAMIS (CAP476) Old-style publication for older aircraft - and MRAs (CAP747) which is a newer style regulation that has subsumed some larger fleets of older aircraft (but has left behind many other older fleets) and includes many newer types.

Just because the old regulations aren’t updated doesn’t necessarily mean they won’t be used by someone.

By doing this it is possible to maintain the standard required by a particular design, and not compromise new standards by mixing them with non-compliant aircraft.

From what I’ve heard (which, to be honest, isn’t much) I believe the newer reg’s may be something more akin to civil standards or even the MAOS standards than their predecessors. If so they could well work, although if the military have had their way they will have turned a comprehensive suite of simple rules into an administrative monster.

We can only live in hope that a sense of simplification has been predominant (but I don’t hold that much hope)

Regarding the above Bold comments: I am led to believe there are moves afoot to recruit some “experienced” SNCOs to conduct some MAA-type duties that may include some form of ARC surveying? – Remember what I said about complicating simple rules?
Wait one……

[Mandator]

Hi Rigga: You are right that in civvy street old design standards remain in use alongside the modern standards. However, beware 'grandfathering' design standards. Some aircraft with design origins which go back to the 50s may not have had the fatigue implications of the design considered to a standard we would expect of a modern aircraft. EASA has just done an NPA and CRD on changes to the AMC & GM to either CS25 or AMC 20 (the latter I think). These tighten up on the use of grandfathering, making TC holders use more modern standards rather than reverting back to the old, and presumably less rigorous, standards.

[tucumseh]

While Old vs New standards is indeed a problem to be overcome by MoD on any old design and, indeed, "modern" standards tend to be more stringent in certain areas, I do not think this is the cause of MoD's systemic failings.


Rather, they should look to those who formally ruled that the likes of JSP553, Def Stan 00-970 and the procedural standards (05-series) could be completely ignored.


All you have to do is map the recommendations of various BoI reports (Nimrod, Hercules, Sea King, Tornado etc) to mandated requirements laid down in these Standards and ask why they were not implemented in the first place.


The same applies to Haddon-Cave's report. A 3rd year apprentice could have told you 90% of the content 20 years ago, in far greater detail; and the same senior MoD staffs who made the above rulings were told, with monotonous regularity, over the last 20 years.


It is not the state of the Standards that the MAA has to overcome, it is the ingrained ethos that they can be ignored if it means "saving" money or time; at the expense of safety. That, I am afraid, will take a long time. You only have to look at the senior staff list at AbbeyWood. The MAA and Bernard Gray will meet much resistance. No-one is going to put their hands up and openly admit "Of course I paid off (e.g.) Critical Design Reviews and then waived the need for the CDR". (But luckily we still have the paperwork as evidence!). The only question in my mind is how many years for such a fraud.

[Chugalug2]

Looking in from afar, it seems to me that the problem is not how the MAA goes about its business of enforcing old regulations or new regulations or any regulations, the problem rather is the MAA itself.
The Gross Negligence now laid out for all to see in various threads on this forum, showing that the UK Military Airworthiness Regulations have been systematically suborned over the past three decades by those charged within the MOD and RAF with their implementation and enforcement, cries out for fundamental changes in the system. The most fundamental and urgent change of all is not to produce yet another new organisation within the MOD to attempt such duties, no matter how beguiling the title it assumes, but to remove such responsibility entirely from the MOD. Not only has the MOD been shown to be utterly unfit to be entrusted with these grave life and death duties, it is in any case entirely inappropriate that it should be so no matter the trail of betrayal and calumny now laid bare.
Airworthiness, be it Civil or Military, must not be at the discretion of Provider, Maintainer or Operator, but rather should be enforced upon them from an exterior independent Authority. Thus it is in Civil Aviation but not in Military Aviation. No amount of searching for a Holy Grail quick fix solution will work while that present anomaly pertains.
It is my own belief that Self Regulation is very much the "British Disease" and lies at the root of much that accounts for our poor performance in so many spheres. Whether that be right or wrong, I maintain that it is self evident that Self Regulation in UK Military Airworthiness Provision has failed us completely, not least the many families left bereaved as a direct result of Gross Negligence at the very highest levels of the Chain of Command. Time is of the essence. More prevarication will mean more needless loss of life. It is time to change attitudes, Now!

[Rigga]

Airworthiness, be it Civil or Military, must not be at the discretion of Provider, Maintainer or Operator, but rather should be enforced upon them from an exterior independent Authority.

Well said, Chug. I wish I could have put it better.

[themightyimp]

It is my own belief that Self Regulation is very much the "British Disease"

It is my experience that the US Military self-regulate as do nearly all European ones.......

[Rigga]

"MAWA" may change that attitude by bringing into force a European standard to all EU military airworthiness. But it'll be years yet...

(Don't ya just love the EU?)

[Chugalug2]

tmi:
It is my experience that the US Military self-regulate as do nearly all European ones.......
Good point mighty imp, and I could have expanded on why we are so much worse at it than others but I would merely say that the proof is in the pudding. By the same token you might point out that nearly all European countries operate state run railways that are reasonably priced, punctual, fast, and not particularly overcrowded. We don't and privatisation seems to have brought with it all the "not my job mate" attitudes of BR. These are all broad generalisations of course, and anyway incidental to the main issue.
Self Regulation has failed UK Military Airworthiness Provision because it kills, never mind the cost financially and militarily of the scrapping of whole fleets because they lack airworthiness. If other countries believe it works for them, that is for them to decide. If we have any sense we will man up to this now and admit that it certainly doesn't work for us, and has not done so since at least 1988. If we do not there will be more airworthiness related fatal military air accidents that should have been avoided but were not, even under the auspices of a so called "Military Aviation Authority" department of the MOD.

[tucumseh]

I agree with Chug and would only add that the "baseline" for crashes attributed to systemic airworthiness failings is now, at MoD's own admission, 1987.

So, in the space of about 15 months we've gone from Haddon-Cave's ludicrous claim of 1998, to 1987. Can it get worse?

Big question. Why did H-C claim 1998 when all the evidence he was given (3 years ago) clearly demonstrated 1990 at the latest? I twitch when such evidence is ignored. You must always ask who it protects.