New military aviation 'body' to set up.
Operating Safety Regulation Group
Technical 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.
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.
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.
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.
What's the likelihood of that? - After all, they do own them.
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?
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?
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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?
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
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?
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
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.
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.
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.
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.
Weekendflyer:
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.
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.
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Glass half full
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!
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!
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...
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...
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.
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.
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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!
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!
imp
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?
Two possibly three people and I can name them.
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?
Colonel Cluster:
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.
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.
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?
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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!
Tuc, 50p/hr seems a great rate, look forward to seeing you taken on board.
El Colonel!
we give ourselves a set of regs that are contradictory and confusing.
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.
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.
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.
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.
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.