Haddon-Cave, Airworthiness, Sea King et al (merged)
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Chug
Just because there was an accident due to contravention of regulations does not mean that all contravention of rules/regulations is a bad idea.
Ask yourself why regulations get contravened.
Often it is because people find that it is impossible to accomplish a task without contravening rules/regulations.
This would not be necessary very often if the rules were fit for purpose, but they are not now and it is only getting worse.
And don't try to tell me that it is never necessary to break rules. Rules can never be comprehensive to cover every situation.
That is why we are supposed to put good people in place to judge the correct moment to break the rules.
I honestly believe that the only way we are accomplishing anything in theatre is because we are breaking rules of all sorts and at all levels.
To folow the rules at the moment leads to total lockup.
Just because there was an accident due to contravention of regulations does not mean that all contravention of rules/regulations is a bad idea.
Ask yourself why regulations get contravened.
Often it is because people find that it is impossible to accomplish a task without contravening rules/regulations.
This would not be necessary very often if the rules were fit for purpose, but they are not now and it is only getting worse.
And don't try to tell me that it is never necessary to break rules. Rules can never be comprehensive to cover every situation.
That is why we are supposed to put good people in place to judge the correct moment to break the rules.
I honestly believe that the only way we are accomplishing anything in theatre is because we are breaking rules of all sorts and at all levels.
To folow the rules at the moment leads to total lockup.
Tourist, If the H-C and Lord P reviews had done their job, they would have revealed that the contravention of Military Airworthiness Regulations was not restricted to one type that caused "an accident", but was systemic and potentially affected all UK Military Aviation. Despite the failure to bring that scandal into the public domain, it is nonetheless the unenviable challenge that the MAA has been saddled with. Difficult enough for it to tackle the inbuilt resistance to it from those such as yourself, it is almost impossible, while itself a part of the MOD, for it to tackle the insouciant attitude at the very top of the CoC that allowed an aircraft restricted by its CAR to "switch on operation only" to be granted a Release to Service into RAF Squadron Service. 29 died in such an aircraft. I'm all for ignoring regs if it is essential in an operational tactical situation (I have instanced the "strap hanging" Apache incident before), providing it is reported ASAP. That is an entirely different thing to the UK Military Airworthiness Authority (aka the MOD) knowingly releasing a Grossly Unairworthy Aircraft into Sqn Service. That is against all the Regulations, is scarcely believable yet happened and would appal even your 1920's Engineer, I suspect.
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In my view, the key thing is not knowing just the correct time to break the rules but to make such a decision for the right reasons when armed with the right information. Additionally, any such rule breaking must be made by the person with the right level of responsibility and this should then be documented accordingly so that the poor sod with his hands at the controls doesn't find him, or herself, at the wrong end of an about-face by the decision maker. Current safety thinking is not about arse covering and risk aversion but about informed decision making and the protection of the people who used to get the blame when the excrement hits the rotating air blower.
That is why we are supposed to put good people in place to judge the correct moment to break the rules.
In a healthy system, the "correct moment" will be determined by a good negotiation at all levels in the chain between Government, budget holders, engineers and operators. Sometimes that correct moment is achieved by forcing the Government to cut costs elsewhere.
Like all chains it is only as strong as the weakest link and this is exactly why, over the last twenty years or so, the system has often failed and the demand for an independent authority has become irresistible. The depressing thought is that, if the MAA has the same weaknesses as the system it regulates, the situation will be as bad as tourist fears.
I fear that the FAA will rapidly suffer from the truth of this as the MAA replaces the relatively independent but not perfect Safety regulators with something far worse.
When I was a Quality Manager, one of the popular adages was, "You can't inspect quality into a job, you have to build it in". I fear that the MAA, in the present form, is an attempt to inspect safety into the system. It won't work unless, like some excellent Quality Systems, it ensures that key people at all levels are suitably qualified.
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Sorry tourist Rigga is 100% correct, both of us have come through the military and into civil aviation, I can tell you that civil aviation is far better regulated. Please also note that I was instrumental in the first mil 145 and MAOS being written and approved initially for the Sentinel.
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Tourist:
I'm one of those that is in full agreement with your feelings on this as you can see from my first posts in this thread. My only difference with you is that the paper trail of airworthiness is an absolute requirement. However, each time we mod an airframe in the name of safety that mod must be rigorously examined through the prism of it's effect on operational effectiveness. If the operational effectiveness is detrimentally affected one must take a close look at the likelihood of the mod actually saving life. If that probability is low then the mod should be shelved. If the mod is enacted it must be tested and documented thus maintaining the airworthiness trail.
I believe, given their druthers, the crews taking airframes into combat would much prefer the operationally optimized airframe with elevated risks in some areas than an airframe that has been utterly crippled in the vain attempt to make it completely safe.
I believe that the baseline of "safety" across all areas needs a very dramatic reset left.
The sine wave of safety has swung from very poor in the middle of last century where were were losing our ability to fight due to constant lose of men and machines, to a position now where we are too hamstrung to field competetive aircraft in affordable numbers.
Some of our platforms have become a shadow of what they could be due to regulatory silliness.
The sine wave of safety has swung from very poor in the middle of last century where were were losing our ability to fight due to constant lose of men and machines, to a position now where we are too hamstrung to field competetive aircraft in affordable numbers.
Some of our platforms have become a shadow of what they could be due to regulatory silliness.
I believe, given their druthers, the crews taking airframes into combat would much prefer the operationally optimized airframe with elevated risks in some areas than an airframe that has been utterly crippled in the vain attempt to make it completely safe.
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matkat
I think you misunderstand me.
I totally agree that the civil world is much better regulated, which is why we keep build programs on the civvy register at the moment.
I don't however believe they are more regulated. Just far more practical and reasonable.
It is certainly easier to stick toys on an aircraft on the civvy register.
Airborne
You get absolutely no argument from me on any of that.
I think part of the difference between some of us on here is between what "airworthiness" currently seems to mean to those of us who fly them, and what "airworthiness" should be, which is a system to maximise the risk/cost compromise in terms of engineering, just like the Flight Saftey system should do for the operating.
I think you misunderstand me.
I totally agree that the civil world is much better regulated, which is why we keep build programs on the civvy register at the moment.
I don't however believe they are more regulated. Just far more practical and reasonable.
It is certainly easier to stick toys on an aircraft on the civvy register.
Airborne
You get absolutely no argument from me on any of that.
I think part of the difference between some of us on here is between what "airworthiness" currently seems to mean to those of us who fly them, and what "airworthiness" should be, which is a system to maximise the risk/cost compromise in terms of engineering, just like the Flight Saftey system should do for the operating.
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What changes are you referring to and why do you say this? (I think it's wrong but I'm interested to understand your rationale.)
Sorry about the delay, I have been away.
With reference to the Nimrod specifically...the changes to engineering checks and operating procedures started the day after the accident and continued for months downstream. They are very well documented including on here.
With reference to the various departments in the MOD that deal with this stuff...I was working on a contract with one of them and it got put on hold because "everything is changing around post the Nimrod accident". That quote was well before HC hit the streets and comes from the horses mouth... and when I say horses mouth I mean somebody closer to the HC report than anybody on here.
No need to dwell on it.
Not many people do like the HC report. The families don't because he slagged off the coroner. The airworthiness gang don't because he lifted the stone, then carefully put it back without distrurbing what he found. The maritime community hate it because they think it cost them all their jobs...I could go on but you get my point.
Does anyone know if the MAA has recruited in any CAA expertise, or indeed anyone who has career experience of both military and civil airworthiness regulations?
If the mod is enacted it must be tested and documented thus maintaining the airworthiness trail.
That is precisely what the regulations say. And precisely what the people I talk about ruled need not happen. Especially on Service Engineered Mods.
The mandated Def Stan, subsuming the procedural specification detailing how to do this work, was declared obsolete 2 years ago, without replacement. It had not been implemented since 1992 and I challenge anyone in MoD to produce a copy! (Still got mine).
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Tourist, this extract from H-C explains the cultural issues behind current engineering decisions, which in many cases lead people to not even consider the sound judgement coming there way from the conscientious.
A process-dependent, paper-reliant, ‘box-ticking’ safety culture has developed in the MOD. Any large, complex, hierarchical ‘top-down’ organisation which measures itself by strict adherence to procedures can become a slave to process and paperwork, and find false comfort in compliance and complexity. The MOD has not been immune from these pathogens. A process-dependent and paper-reliant culture has developed, particularly within DE&S and IPTs, which led to a shift away from proper risk analysis and ownership towards a ‘box-ticking’ approach to the management of safety and Airworthiness. Compliance with process and form-filling has taken the place of sound judgment.
Also from the sound of it, even the extant process and procedures were not being followed. Add the two together and you get accidents we have seen recently.
A process-dependent, paper-reliant, ‘box-ticking’ safety culture has developed in the MOD. Any large, complex, hierarchical ‘top-down’ organisation which measures itself by strict adherence to procedures can become a slave to process and paperwork, and find false comfort in compliance and complexity. The MOD has not been immune from these pathogens. A process-dependent and paper-reliant culture has developed, particularly within DE&S and IPTs, which led to a shift away from proper risk analysis and ownership towards a ‘box-ticking’ approach to the management of safety and Airworthiness. Compliance with process and form-filling has taken the place of sound judgment.
Also from the sound of it, even the extant process and procedures were not being followed. Add the two together and you get accidents we have seen recently.
1.3VStall:
"Does anyone know if the MAA has recruited in any CAA expertise, or indeed anyone who has career experience of both military and civil airworthiness regulations? "
Yes, they've had "Bainnes-Simmons" (B-S) as consultants for some time but I'm not sure if that has ended now.
B-S is an aviation industry respected group of consultants recruited mainly from the CAA or Airlines. They are also consultants for many other States for both military and civil regulatory bodies.
However, it's not what B-S told the MAA that you should worry about, but how the MAA translates it into "Mil-Speak" and loses the intent of the original understanding.
From what I understand, the MAA seems to be inventing some new methods of not complying with the clarity of regulation required by H-C.
"Does anyone know if the MAA has recruited in any CAA expertise, or indeed anyone who has career experience of both military and civil airworthiness regulations? "
Yes, they've had "Bainnes-Simmons" (B-S) as consultants for some time but I'm not sure if that has ended now.
B-S is an aviation industry respected group of consultants recruited mainly from the CAA or Airlines. They are also consultants for many other States for both military and civil regulatory bodies.
However, it's not what B-S told the MAA that you should worry about, but how the MAA translates it into "Mil-Speak" and loses the intent of the original understanding.
From what I understand, the MAA seems to be inventing some new methods of not complying with the clarity of regulation required by H-C.
"If the mod is enacted it must be tested and documented thus maintaining the airworthiness trail."
In the specific cases for Urgent Operational necessity - I rather embarrasingly disagree.
I would quote the successful "Bodge-Tape and Bean Can" AAR Modifications of Hercs and Nimrods for the Falklands campaign, where an urgent mod was needed and devised (though not designed) by physical trial and error.
These "STFs" were then removed AFTER the conflict and properly designed and supported by OEMs.
This function IS catered for in the MAOS regs (as it is in EASA) but you need to know where to look and how to translate it.
The STF is the fit-for-purpose bit (I call it Mission Capability) and the Safety and Airworthiness bits come in when the STF is inhibited or removed as it is no longer an urgent requirement.
Though the STF can't remain installed indefinately - It can be used if NEEDED, and not just wanted.
Tourist,
If you write what you mean - I may not be such a pedant.
As some sort of aircrew, you should know something of the CRM character type you are portraying in this thread.
In the specific cases for Urgent Operational necessity - I rather embarrasingly disagree.
I would quote the successful "Bodge-Tape and Bean Can" AAR Modifications of Hercs and Nimrods for the Falklands campaign, where an urgent mod was needed and devised (though not designed) by physical trial and error.
These "STFs" were then removed AFTER the conflict and properly designed and supported by OEMs.
This function IS catered for in the MAOS regs (as it is in EASA) but you need to know where to look and how to translate it.
The STF is the fit-for-purpose bit (I call it Mission Capability) and the Safety and Airworthiness bits come in when the STF is inhibited or removed as it is no longer an urgent requirement.
Though the STF can't remain installed indefinately - It can be used if NEEDED, and not just wanted.
Tourist,
If you write what you mean - I may not be such a pedant.
As some sort of aircrew, you should know something of the CRM character type you are portraying in this thread.
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AA and others,
I see your points on airworthiness. If you want to use the word to describe the suitability (and implicitly the safety) of an aircraft to be released to service, then I can see why the word fits - however, when it comes to actually demonstrating that 'airworthiness' the disciplines used are essentially those of the safety engineers. In BAES, there was an interesting battle going on a few years ago between the 'airworthiness' department and the emerging 'safety' discipline.
That's why I see 'airworthiness' and 'safety' as shades of grey in the overall picture. That said, not one to fall out over, I hope.
One point I'd like to make is that it doesn't help our aircrew to take a purely 'black and white' view over who 'owns what piece of safety. To reiterate my point, my experience is that safety (and airworthiness) are best served when aircrew and engineers work together through a whole life cycle of an aircraft to achieve the correct balance between safety and operability of the weapon system. Here's an example.
On a recent project, we had to introduce a new set of external safety pins for an armament system. Many aircrew hated the idea, and opposed it all the way. Objections were raised such as:
1. What was wrong with the old system of one pin inside the cabin - it's easier and we know how to work it.
2. Four external pins are a bad idea, because someone will forget to take them out....
We held out, and went for the additional external pins. Why? Because they are safer. Why? because they allow a shorter run of cable between the pin and the dispensers. That reduces EMC vulnerability. (Useful for when we go to sea) They also provide an excellent external indication of the armament state of the aircraft. Finally, it brings the system into compliance with important DefStans that are sensible and achievable.
Here's my point. It's not the aircrew's job to know that detail. It's the engineers'. Working as a team, we addressed the issue and decided how we were going to do the job to achieve maximum safety without compromising operational capability. We engineers could not have done that without the aircrew and they couldn't have done it without us.
I also agree with Tourist that it is very nearly impossible to design a military aircraft that meets every single aspect of all the Def Stans and other requirements, and it's probably counterproductive even to try. The team has to work out where (use use a naval term) to 'veer and haul'. That's where the professionals come in handy.
best Regards as ever
Engines
I see your points on airworthiness. If you want to use the word to describe the suitability (and implicitly the safety) of an aircraft to be released to service, then I can see why the word fits - however, when it comes to actually demonstrating that 'airworthiness' the disciplines used are essentially those of the safety engineers. In BAES, there was an interesting battle going on a few years ago between the 'airworthiness' department and the emerging 'safety' discipline.
That's why I see 'airworthiness' and 'safety' as shades of grey in the overall picture. That said, not one to fall out over, I hope.
One point I'd like to make is that it doesn't help our aircrew to take a purely 'black and white' view over who 'owns what piece of safety. To reiterate my point, my experience is that safety (and airworthiness) are best served when aircrew and engineers work together through a whole life cycle of an aircraft to achieve the correct balance between safety and operability of the weapon system. Here's an example.
On a recent project, we had to introduce a new set of external safety pins for an armament system. Many aircrew hated the idea, and opposed it all the way. Objections were raised such as:
1. What was wrong with the old system of one pin inside the cabin - it's easier and we know how to work it.
2. Four external pins are a bad idea, because someone will forget to take them out....
We held out, and went for the additional external pins. Why? Because they are safer. Why? because they allow a shorter run of cable between the pin and the dispensers. That reduces EMC vulnerability. (Useful for when we go to sea) They also provide an excellent external indication of the armament state of the aircraft. Finally, it brings the system into compliance with important DefStans that are sensible and achievable.
Here's my point. It's not the aircrew's job to know that detail. It's the engineers'. Working as a team, we addressed the issue and decided how we were going to do the job to achieve maximum safety without compromising operational capability. We engineers could not have done that without the aircrew and they couldn't have done it without us.
I also agree with Tourist that it is very nearly impossible to design a military aircraft that meets every single aspect of all the Def Stans and other requirements, and it's probably counterproductive even to try. The team has to work out where (use use a naval term) to 'veer and haul'. That's where the professionals come in handy.
best Regards as ever
Engines
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Small spinner:
"A process-dependent, paper-reliant, ‘box-ticking’ safety culture has developed in the MOD. Any large, complex, hierarchical ‘top-down’ organisation which measures itself by strict adherence to procedures can become a slave to process and paperwork, and find false comfort in compliance and complexity. The MOD has not been immune from these pathogens. A process-dependent and paper-reliant culture has developed, particularly within DE&S and IPTs, which led to a shift away from proper risk analysis and ownership towards a ‘box-ticking’ approach to the management of safety and Airworthiness. Compliance with process and form-filling has taken the place of sound judgment."
Just like it has inside the CAA.
"A process-dependent, paper-reliant, ‘box-ticking’ safety culture has developed in the MOD. Any large, complex, hierarchical ‘top-down’ organisation which measures itself by strict adherence to procedures can become a slave to process and paperwork, and find false comfort in compliance and complexity. The MOD has not been immune from these pathogens. A process-dependent and paper-reliant culture has developed, particularly within DE&S and IPTs, which led to a shift away from proper risk analysis and ownership towards a ‘box-ticking’ approach to the management of safety and Airworthiness. Compliance with process and form-filling has taken the place of sound judgment."
Just like it has inside the CAA.
Mandator, whatever the shortcomings of the CAA, and no doubt there are many, it doesn't as far as I know conspire to subvert its own airworthiness regulations. Give thanks for that, and help ensure that the same consideration be given to Military Airworthiness. Whatever way that can be done, I cannot see how it can be achieved from within the MOD, even "independently". Leopards and spots, I'm afraid, Leopards and spots!
Self Regulation does not work and in Aviation it Kills!
Self Regulation does not work and in Aviation it Kills!
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Mandator
You are right, there is a tendency for all organisations to fall back on box ticking, and ignore good advice, because it might cost money. Doing the minimum, and not embracing the safety culture is an easy way out, even with all the SMS systems, Human Factors programs etc
You are right, there is a tendency for all organisations to fall back on box ticking, and ignore good advice, because it might cost money. Doing the minimum, and not embracing the safety culture is an easy way out, even with all the SMS systems, Human Factors programs etc
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Chug:
I agree that the CAA does not try to subvert its own or the EASA regulations, and it is now much more open in its development of new (national - ie, non-EASA) regulations. However, it has become a box-ticking, process-led organisation and the H-C description is a good fit.
I agree that the CAA does not try to subvert its own or the EASA regulations, and it is now much more open in its development of new (national - ie, non-EASA) regulations. However, it has become a box-ticking, process-led organisation and the H-C description is a good fit.
Mandator
That's a shame about the CAA. No point in me suggesting MoD return to the time when we were formally examined against CAA regulations before being allowed remotely near an aircraft component, never mind an aircraft!! We even had to buy our own CAIP leaflets.
That's a shame about the CAA. No point in me suggesting MoD return to the time when we were formally examined against CAA regulations before being allowed remotely near an aircraft component, never mind an aircraft!! We even had to buy our own CAIP leaflets.
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Rigga,
I have to disagree with your last post on modifications. ANY modification has to be adequately tested and cleared, with the necessary degree of rigour to provide an airworthiness trail. As I have said, it's up to the professionals to determine how much 'adequately' and 'necessary' mean. That means we can support the aircrew. But the bottom line is that there HAS to be some level of documentation and testing to cover the safe use of the modification, and to allow the user to know what the state of the aircraft actually is.
Where I have to disagree more strongly though, is the use of STFs. In my professional view, this was a systemic problem with the RAF. STF, as I'm sure you know, stood for Special Trial Fit. AP100 was very clear about how they were supposed to be used. In my direct experience, the RAF completely abused the STF and used it to get around doing the necessary level of clearance and documentation for operational modifications, not trials. The number of STFs that got fitted and remained fitted for years ran into many hundreds and I felt that each one was a disgrace.
When I took over as SO1 A4 for one RAF fast jet fleet, I found various aircraft flying around with combinations of 7 different STFs fitted. I gave the IPT four months to either get them converted to SEMs (as was) or get them off the fleet. Four months later, three were SEMs, four had been removed as no longer required.
Abuse of STFs is a good example of how teamwork breaks down - engineers being given ridiculously short time frames to put modifications on, and being told (by aircrew) to 'just use an STF - we'll get an OEC'. (I heard this sort of stuff frequently at Strike). The correct response would have been 'it will take x days/weeks to get a SEM done, and that's when you will get it'. However, in the RAF, the more usual response I heard was 'yes, sir.'
The new JAP SM process is basically quite good, although there is an element of 'box ticking' going on. It's workable and if used sensibly and professionally, can get mods on to aircraft quickly and effectively. There is some turbulence in the RTS/MAA area, but again I believe it can be managed through.
Best Regards as ever
Engines
I have to disagree with your last post on modifications. ANY modification has to be adequately tested and cleared, with the necessary degree of rigour to provide an airworthiness trail. As I have said, it's up to the professionals to determine how much 'adequately' and 'necessary' mean. That means we can support the aircrew. But the bottom line is that there HAS to be some level of documentation and testing to cover the safe use of the modification, and to allow the user to know what the state of the aircraft actually is.
Where I have to disagree more strongly though, is the use of STFs. In my professional view, this was a systemic problem with the RAF. STF, as I'm sure you know, stood for Special Trial Fit. AP100 was very clear about how they were supposed to be used. In my direct experience, the RAF completely abused the STF and used it to get around doing the necessary level of clearance and documentation for operational modifications, not trials. The number of STFs that got fitted and remained fitted for years ran into many hundreds and I felt that each one was a disgrace.
When I took over as SO1 A4 for one RAF fast jet fleet, I found various aircraft flying around with combinations of 7 different STFs fitted. I gave the IPT four months to either get them converted to SEMs (as was) or get them off the fleet. Four months later, three were SEMs, four had been removed as no longer required.
Abuse of STFs is a good example of how teamwork breaks down - engineers being given ridiculously short time frames to put modifications on, and being told (by aircrew) to 'just use an STF - we'll get an OEC'. (I heard this sort of stuff frequently at Strike). The correct response would have been 'it will take x days/weeks to get a SEM done, and that's when you will get it'. However, in the RAF, the more usual response I heard was 'yes, sir.'
The new JAP SM process is basically quite good, although there is an element of 'box ticking' going on. It's workable and if used sensibly and professionally, can get mods on to aircraft quickly and effectively. There is some turbulence in the RTS/MAA area, but again I believe it can be managed through.
Best Regards as ever
Engines