New military aviation 'body' to set up.
"...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!
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!
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:
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!
There still needs to be some REGULATORS that actually can REGULATE!
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?
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?
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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
"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
"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,
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!
Safeware & Rigga
Thank you. It was just that the phrase
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.
Thank you. It was just that the phrase
A few consultants milling around with the MAA
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.
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.
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.
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tucumseh writes:
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:
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.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!
They really do have to learn that Chinook, C130, Nimrod etc occurred because mandated regs were not implemented, not because the regs were wrong.
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 
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 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!
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……
"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……
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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.
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.
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.
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!
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!
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.
Well said, Chug. I wish I could have put it better.
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Originally Posted by ChugaLug2
It is my own belief that Self Regulation is very much the "British Disease"
tmi:
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.
It is my experience that the US Military self-regulate as do nearly all European ones.......
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.
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.
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.
