Martin Baker to be prosecuted over death of Flt Lt. Sean Cunningham
Exrigger
Thanks. If you just take the first one, RA4970, para 2 (Tolerable and ALARP).....
Completely ignored in this XX177 case. MoD denied it knew the area of risk was NOT ALARP. It concealed the evidence that showed it not to be ALARP since 1990, and that it had rejected the modification that would eliminate the risk. When revealed (last month), MoD and HSE declared it irrelevant. I'm afraid I have no confidence in the MAA when they tolerate this.
This RA doesn't introduce the concept of tolerable and ALARP. Like most MAA documents, it simply re-phrases existing and perfectly good procedures, regulations and instructions. I'm sorry if I upset anyone, but there are a raft, perhaps hundreds of 'SO3/2/1' working on these as if they were staff papers, oblivious to the fact that very junior MoD staff know it all backwards, and laugh at the ineptitude of it all. I learned a lot of this stuff from a 4th year apprentice, when I was a year behind him. And God knows I was backward and a slow learner.
Thanks. If you just take the first one, RA4970, para 2 (Tolerable and ALARP).....
Completely ignored in this XX177 case. MoD denied it knew the area of risk was NOT ALARP. It concealed the evidence that showed it not to be ALARP since 1990, and that it had rejected the modification that would eliminate the risk. When revealed (last month), MoD and HSE declared it irrelevant. I'm afraid I have no confidence in the MAA when they tolerate this.
This RA doesn't introduce the concept of tolerable and ALARP. Like most MAA documents, it simply re-phrases existing and perfectly good procedures, regulations and instructions. I'm sorry if I upset anyone, but there are a raft, perhaps hundreds of 'SO3/2/1' working on these as if they were staff papers, oblivious to the fact that very junior MoD staff know it all backwards, and laugh at the ineptitude of it all. I learned a lot of this stuff from a 4th year apprentice, when I was a year behind him. And God knows I was backward and a slow learner.
Post 462 - Engines
You wouldn't happen to know the initials of this Gp Capt engineer would you. It's just that, coincidence or what, my wife has invited some new neighbours for dinner this evening and he is a retired Gp Capt engineer. I know that this subject will come up because he has just finished reading "Their Greatest Disgrace" by David Hill. I am looking forward to hearing his views.
(To their considerable credit, a very smart Gp Capt engineer did just that a couple of years later - I cherish a hope that the sight of the RN's slimline stack of books might have helped start that process).
Tucumseh, having worked within these so called new regulations within civilian companies and having spent the 30 years previous trying to maintain safety/airworthiness IAW the same regulations that they came from, I was, in both cases, frustrated, annoyed and numerous occasions brought the wrath of management on myself when I pointed out the more flagrant mis-interpretations, or non-compliances, even when I submitted amendments to remove introduced errors which were turned down.
I do get down when the avoidable is repeated by the lack of understanding of, erosion of, or the ignoring of those very sytems meant to stop these occurrences, surely they must wake up and realise this, the evidence is there for all to see.
I do get down when the avoidable is repeated by the lack of understanding of, erosion of, or the ignoring of those very sytems meant to stop these occurrences, surely they must wake up and realise this, the evidence is there for all to see.
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Is there a third way?
I think the thread is pointing towards, for each type in service, they either;
Write the book from scratch.
Or,
Go back to version 1 and amend it carefully with full input from manufacturers and engineers. Documenting along the way.
The MoD should of course, stop flying until the books are complete, and procedures are in place. But only if they want stop people dying in them.
Unthinkable perhaps.
How unthinkable is another preventable death?
I think the thread is pointing towards, for each type in service, they either;
Write the book from scratch.
Or,
Go back to version 1 and amend it carefully with full input from manufacturers and engineers. Documenting along the way.
The MoD should of course, stop flying until the books are complete, and procedures are in place. But only if they want stop people dying in them.
Unthinkable perhaps.
How unthinkable is another preventable death?
Exrigger,
Due to my civil airline maintenance and operations experiences, I too was once employed to try and implement MIL Part M (at the time it was Def Stan 05-130 - MAOS Part M) to the Company I worked with and also to educate and advise the RAF contingent with my scope of work.
I have to say that I did make some large waves in changing company and some RAF attitudes to the MAOS regulations and their associated processes. However, there was also a great deal of resistance/retaliation from the customer against their own regulations. I managed to hold my job for four years before giving up in sheer frustration, with the customer attitudes, and going back to civvy street where I had a much less stressful time holding nine EASA Forms 4.
In that relatively short tenure, I found that the (quite hostile) EA had no clue as to how they should respond to reliability reports or any other findings from their contractors, to the point where the EA were forced to surrender there maintenance program duties (and the cost of a £6m contract) because their 'avoidance of airworthiness actions' were placed on a company Risk Register and displayed to their DH.
That EA had no method of recording or even researching defect trends within their single platform and displayed some 'alternate' priorities in their duties. In fact their own history documented the EA's lack of action and attention for the previous 20 years!
Due to my civil airline maintenance and operations experiences, I too was once employed to try and implement MIL Part M (at the time it was Def Stan 05-130 - MAOS Part M) to the Company I worked with and also to educate and advise the RAF contingent with my scope of work.
I have to say that I did make some large waves in changing company and some RAF attitudes to the MAOS regulations and their associated processes. However, there was also a great deal of resistance/retaliation from the customer against their own regulations. I managed to hold my job for four years before giving up in sheer frustration, with the customer attitudes, and going back to civvy street where I had a much less stressful time holding nine EASA Forms 4.
In that relatively short tenure, I found that the (quite hostile) EA had no clue as to how they should respond to reliability reports or any other findings from their contractors, to the point where the EA were forced to surrender there maintenance program duties (and the cost of a £6m contract) because their 'avoidance of airworthiness actions' were placed on a company Risk Register and displayed to their DH.
That EA had no method of recording or even researching defect trends within their single platform and displayed some 'alternate' priorities in their duties. In fact their own history documented the EA's lack of action and attention for the previous 20 years!
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Duty Holder's Accountability
The following is an extract from the evidence given by Air Marshal Richard Garwood to the Defence Committee, in respect to Duty of Care, on 29th Nov 2016.
"I think it goes back to, as Sir Charles Haddon-Cave put forward in his report, that this must be about personal accountability and not corporate or wider accountability. That is why we now have the three-layered or four-layered Duty Holder construct with the fourth being the Secretary of State for Defence. If we had a fatality in the military tomorrow, I could give you the four names for any part of military defence who have accepted personal accountability for that. Perhaps I could refer to one of our Duty Holder letters from the Chief of the Air Staff, Sir Andrew Pulford to Air Vice Marshal Turner, who is an Operating Duty Holder. Line 4 of the letter says: “You are personally legally responsible and accountable through the Secretary of State for air safety, the air systems and functional safety in your area of responsibility.” We are now crystal clear in the military about where that accountability lies and it is not at lower levels, but at pretty senior levels: Lieutenant Colonel up to Chief of the Air Staff in this instance, and above to the Secretary of State."
RA 1210 makes it clear that in the event of a fatality the Duty Holder is expected to defend his Safety statement in a court of law. So where were these guys in the Red Arrow case? In fact where were these guys in Tornado collision case, the Lynx case, the Puma case? In the shadows protecting their pensions. The MAA regulations are just "paper talk" that have got nothing to do with airworthiness and saving lives. Since the introduction of Haddon-Cave's duty holder concept not one senior officer has been called on to defend his safety statement (Tolerable and ALARP) in a court of law.
In recent email the MAA advised me that, "It should be noted that the validity of an ALARP argument can only be decided definitively by the courts, in the event of an accident". Do coroners and judges know that?
DV
"I think it goes back to, as Sir Charles Haddon-Cave put forward in his report, that this must be about personal accountability and not corporate or wider accountability. That is why we now have the three-layered or four-layered Duty Holder construct with the fourth being the Secretary of State for Defence. If we had a fatality in the military tomorrow, I could give you the four names for any part of military defence who have accepted personal accountability for that. Perhaps I could refer to one of our Duty Holder letters from the Chief of the Air Staff, Sir Andrew Pulford to Air Vice Marshal Turner, who is an Operating Duty Holder. Line 4 of the letter says: “You are personally legally responsible and accountable through the Secretary of State for air safety, the air systems and functional safety in your area of responsibility.” We are now crystal clear in the military about where that accountability lies and it is not at lower levels, but at pretty senior levels: Lieutenant Colonel up to Chief of the Air Staff in this instance, and above to the Secretary of State."
RA 1210 makes it clear that in the event of a fatality the Duty Holder is expected to defend his Safety statement in a court of law. So where were these guys in the Red Arrow case? In fact where were these guys in Tornado collision case, the Lynx case, the Puma case? In the shadows protecting their pensions. The MAA regulations are just "paper talk" that have got nothing to do with airworthiness and saving lives. Since the introduction of Haddon-Cave's duty holder concept not one senior officer has been called on to defend his safety statement (Tolerable and ALARP) in a court of law.
In recent email the MAA advised me that, "It should be noted that the validity of an ALARP argument can only be decided definitively by the courts, in the event of an accident". Do coroners and judges know that?
DV
DV
Excellent.
But who determines who appears in court to answer? It seems to be MoD, and the judiciary and Coroner's Service roll over. One of the more obvious examples was at the Mull of Kintyre Fatal Accident Inquiry (into the deaths of the RUC and civilian MI5 officers - not the Service personnel - a subtlety which I know interests you). The families were looking forward to engaging with the Air Marshals, but they were a no show. The MoD QC immediately asked the Sheriff to confirm that, if the author of evidence was not in court, then that evidence could not be produced. He agreed. (Probably had to agree, if that is the law). This renders RA1210 meaningless.
Possibly the most senior officer to appear is Admiral Massey, at the Sea King ASaC mid-air inquest in 2007. His evidence was tainted straight away by claiming the Mk7 is a two-pilot aircraft, and that two pilots (even if there were two) render electronic sensors redundant. So, it didn't matter that they were degraded in one aircraft, and not switched on in the other. His evidence is relevant to this Red Arrows case, because it reveals serous ignorance of the concept of defences in depth. Flt Lt Cunningham's parachute was the final defence. Seldom is it mentioned that a number of other defences failed entirely. None were Martin-Baker responsibilities. They didn't fail by accident. Many were as a result of MoD's policy and practice of savings at the expense of safety. If you strip away defences, the outcome is easily foreseen.
Excellent.
But who determines who appears in court to answer? It seems to be MoD, and the judiciary and Coroner's Service roll over. One of the more obvious examples was at the Mull of Kintyre Fatal Accident Inquiry (into the deaths of the RUC and civilian MI5 officers - not the Service personnel - a subtlety which I know interests you). The families were looking forward to engaging with the Air Marshals, but they were a no show. The MoD QC immediately asked the Sheriff to confirm that, if the author of evidence was not in court, then that evidence could not be produced. He agreed. (Probably had to agree, if that is the law). This renders RA1210 meaningless.
Possibly the most senior officer to appear is Admiral Massey, at the Sea King ASaC mid-air inquest in 2007. His evidence was tainted straight away by claiming the Mk7 is a two-pilot aircraft, and that two pilots (even if there were two) render electronic sensors redundant. So, it didn't matter that they were degraded in one aircraft, and not switched on in the other. His evidence is relevant to this Red Arrows case, because it reveals serous ignorance of the concept of defences in depth. Flt Lt Cunningham's parachute was the final defence. Seldom is it mentioned that a number of other defences failed entirely. None were Martin-Baker responsibilities. They didn't fail by accident. Many were as a result of MoD's policy and practice of savings at the expense of safety. If you strip away defences, the outcome is easily foreseen.
Exactly tuc! Anyone can make reassuring commitments to ruthlessly holding VSO Duty Holders to account, but it is by their actions that we should judge them. In reality none of them are held to account but instead protected with a tissue of lies of omission and commission, and by persecuting their juniors in life and even in death. The whole concept that the MOD, the perpetrator in this scandal, should be judge and jury of its own case is risible.
If the results of this dysfunctional and corrupt system were not so tragic it would make for an amusing plot for Yes Minister. There is nothing amusing or redeeming about the MOD. No matter how the goal posts are moved or relabelled, UK Military Air Safety remains at the mercy of further subversion and suborning by VSOs. It has to be freed from their grasp, and Regulator and Investigator made independent of the MOD and of each other.
If the results of this dysfunctional and corrupt system were not so tragic it would make for an amusing plot for Yes Minister. There is nothing amusing or redeeming about the MOD. No matter how the goal posts are moved or relabelled, UK Military Air Safety remains at the mercy of further subversion and suborning by VSOs. It has to be freed from their grasp, and Regulator and Investigator made independent of the MOD and of each other.
Perhaps I should add it was slightly unfair of me to mention Admiral Massey, as he had the decency to appear - unlike others. I'm sure he understands the concept in the context of being boss of a carrier group. I'm equally sure the families would have preferred to hear from the MoD employees who lied to the Board of Inquiry and other investigations.
In this case, I'm sure Mr Cunningham would have wished to hear why the modification that would have saved his son was not adopted in 1990. Even the judge expressed concern that MoD's star witness wasn't in court. And as for the HSE's star witness.... Are safety cases now irrelevant to the decision to release to service? Has the MAA changed things so much?
In this case, I'm sure Mr Cunningham would have wished to hear why the modification that would have saved his son was not adopted in 1990. Even the judge expressed concern that MoD's star witness wasn't in court. And as for the HSE's star witness.... Are safety cases now irrelevant to the decision to release to service? Has the MAA changed things so much?
Rigga, we are talking the same groups of people, just different platforms.
As to the MAA in its entirety, it makes one wonder how they can take the regulatory set from the CAA to align the military with that system, a system (CAA's) that would appear to be robust and work within civilian aviation, convert it into a system that they did not appear to know how to integrate it within the military system, causes issues for civilian contractors who find it hard to work within both systems, especialy when the military one appears confusing, and in some parts makes no sense after translation into military speak.
Was was this done on purpose, I highly doubt it, was it lack of knowledge of those who wanted to make the change, thinking it might make things better within the military and just translated it incorrectly, was it the lack of understanding that got them where they currently are, is there the will and knowledge to fix it, do they actualy believe it is not working as advertised, do those at the top want it fixing, as it would appear that the obfuscation of safety/airworthiness systems could actually keep those at the top out of reach when issues arise, issues like the subject of this thread and many more.
I will state that these are my observations from my involvement on various platforms since inception, but hopefully things noted above and in other posts may have been, or in the progress of being fixed, only those still working today, both civilian and military can answer that, would presume it would also depend on where in the food chain those people sit as to whether it is ok, or not, though historically the higher up the person is, the less there are perceived problems.
As I posted before the BMAR should have picked up these issues with work carried out, inclding, MODs, SI's etc, or not as the case may be, and the annual MAR should maintain that survellience of work done, or what should of been done, before issuing the next years certificate to fly.
As to the MAA in its entirety, it makes one wonder how they can take the regulatory set from the CAA to align the military with that system, a system (CAA's) that would appear to be robust and work within civilian aviation, convert it into a system that they did not appear to know how to integrate it within the military system, causes issues for civilian contractors who find it hard to work within both systems, especialy when the military one appears confusing, and in some parts makes no sense after translation into military speak.
Was was this done on purpose, I highly doubt it, was it lack of knowledge of those who wanted to make the change, thinking it might make things better within the military and just translated it incorrectly, was it the lack of understanding that got them where they currently are, is there the will and knowledge to fix it, do they actualy believe it is not working as advertised, do those at the top want it fixing, as it would appear that the obfuscation of safety/airworthiness systems could actually keep those at the top out of reach when issues arise, issues like the subject of this thread and many more.
I will state that these are my observations from my involvement on various platforms since inception, but hopefully things noted above and in other posts may have been, or in the progress of being fixed, only those still working today, both civilian and military can answer that, would presume it would also depend on where in the food chain those people sit as to whether it is ok, or not, though historically the higher up the person is, the less there are perceived problems.
As I posted before the BMAR should have picked up these issues with work carried out, inclding, MODs, SI's etc, or not as the case may be, and the annual MAR should maintain that survellience of work done, or what should of been done, before issuing the next years certificate to fly.
Tecumseh and engines, thank you, gentlemen, for your detailed reply.
Having read the SI it still sticks in my craw that M.B. were fined for not protecting the RAF
from itself ( at least that is how it appears to me) as there is a list of 14 contributory factors in that SI.
The one item, of several, which really disturbs me is that there was a practice of inserting the. SFH pin WITHOUT visual reference, hard to believe that such a safety critical item was so (mis) managed.
Another thing which I do not understand, and to which no one has yet given a reasonable answer:
If the pin was removed before engine start it follows that taxi OUT was conducted with a live seat.
Why, then, was the SFH pin replacement not left in place during the taxi IN and carefully replaced, with visual observation and confirmation of correct replacement, on reaching the pan and the engine shut down ?
It’s a long time since I was a QFI, (and my own ejection) but I just cannot begin to understand why such an unsafe practice was allowed, tolerated, let alone became an SOP.
Has that practice been changed following this tragic death ?
Having read the SI it still sticks in my craw that M.B. were fined for not protecting the RAF
from itself ( at least that is how it appears to me) as there is a list of 14 contributory factors in that SI.
The one item, of several, which really disturbs me is that there was a practice of inserting the. SFH pin WITHOUT visual reference, hard to believe that such a safety critical item was so (mis) managed.
Another thing which I do not understand, and to which no one has yet given a reasonable answer:
If the pin was removed before engine start it follows that taxi OUT was conducted with a live seat.
Why, then, was the SFH pin replacement not left in place during the taxi IN and carefully replaced, with visual observation and confirmation of correct replacement, on reaching the pan and the engine shut down ?
It’s a long time since I was a QFI, (and my own ejection) but I just cannot begin to understand why such an unsafe practice was allowed, tolerated, let alone became an SOP.
Has that practice been changed following this tragic death ?
Certainly on my own fleet the pin is shown to the ground crew prior to taxy, then inserted into the stowage which is below the cockpit sides.
Exrigger
-re CAA. As an MoD apprentice, I was examined against both MoD's rules and procedures, and the CAA's Civil Aircraft Inspection Procedures. Even had to buy our own CAIP Leaflets! Still got them. To me, this demonstrates MoD had very close links to the CAA. Is the wheel being reinvented again? When did MoD stop training its maintainers to both sets of rules?
-re CAA. As an MoD apprentice, I was examined against both MoD's rules and procedures, and the CAA's Civil Aircraft Inspection Procedures. Even had to buy our own CAIP Leaflets! Still got them. To me, this demonstrates MoD had very close links to the CAA. Is the wheel being reinvented again? When did MoD stop training its maintainers to both sets of rules?
Tucumseh, I am not able to answer those types of questions, as from my involvement I was only ever applying the military version and trying to get the military side to work to those and together, but it was often a wasted effort.
My posts have been based on my experiences, and I have been out of a constantly changing environment for a while, which is why it would be interesting to get a view of the current 'in work' personnel from both military and civilian personnel on bases to provide their view of the system today, something I would be very interested in.
Of note, the Lead Auditors for MRP-145 approvals are usually from the CAA, which has produced some interesting 'audit' findings.
My posts have been based on my experiences, and I have been out of a constantly changing environment for a while, which is why it would be interesting to get a view of the current 'in work' personnel from both military and civilian personnel on bases to provide their view of the system today, something I would be very interested in.
Of note, the Lead Auditors for MRP-145 approvals are usually from the CAA, which has produced some interesting 'audit' findings.
Tuc and Exrigger,
From my POV the resistance to regulatory change came from the embryonic MAA itself. I met and chatted with the guy who drafted 05-130 (Parts 145 and M) who said that it was messed about after 'acceptance' of the draft and prior to publishing. The dis-jointedness of its content shocked him.
Shortly after my first reading of Mil Part M, I noticed that it could not work because someone had not permitted the issue of a 'MIL Form 1', an essential part of that regulatory system. I assumed, rightly or wrongly, that this was down to the powers in MOD reading 'Form 1' as simple replacement for a 'Serviceable Label' (MOD Form 735) and ignoring it. i.e. they didn't understand the Form 1s significance.
Those MAOS and DAOS standards defined personnel responsible for tasks and part of my job was to educate, explain and clarify why the Accountable Manager (which became the nominated DH) could not be a Group Captain and had to be the budget holder, not a mere budget manager. i.e. the person who gave the Group Captain his budget to manage.
Post H-C, the first thing the MAA did was not to try and adopt the MAOS/DAOS standards, but to squeeze the bits of those standards into where they already "complied" and then set about re-wording all the other bits (through issuing the new set of RAs) to suit the status quo. In essence: some Post-It Notes had been placed on the regulatory wall, but all the cracks had only been cleaned, not even whitewashed, to look more presentable.
The use of Airworthiness Reviews fell at their first attempt when that aircraft failed the very first AR question (it did not have a valid Maintenance Programme) but this was ignored by a certain Eng O and stated as a Pass! (I again assumed that this Eng O was chasing a promotion rather than proving a system worked)
As for training standards, there are now serving technicians with EASA Part 66 licences to allow them to work on A330, A400, G500, Beech350 and the like. Also, I believe the Cosford syllabus is similar to EASA standards, probably because MOD can't staff its own full training syllabus. Finally, the EU Mil Airworthiness Regs (EMARs) also cover technician training so there may be some input there too.
From my POV the resistance to regulatory change came from the embryonic MAA itself. I met and chatted with the guy who drafted 05-130 (Parts 145 and M) who said that it was messed about after 'acceptance' of the draft and prior to publishing. The dis-jointedness of its content shocked him.
Shortly after my first reading of Mil Part M, I noticed that it could not work because someone had not permitted the issue of a 'MIL Form 1', an essential part of that regulatory system. I assumed, rightly or wrongly, that this was down to the powers in MOD reading 'Form 1' as simple replacement for a 'Serviceable Label' (MOD Form 735) and ignoring it. i.e. they didn't understand the Form 1s significance.
Those MAOS and DAOS standards defined personnel responsible for tasks and part of my job was to educate, explain and clarify why the Accountable Manager (which became the nominated DH) could not be a Group Captain and had to be the budget holder, not a mere budget manager. i.e. the person who gave the Group Captain his budget to manage.
Post H-C, the first thing the MAA did was not to try and adopt the MAOS/DAOS standards, but to squeeze the bits of those standards into where they already "complied" and then set about re-wording all the other bits (through issuing the new set of RAs) to suit the status quo. In essence: some Post-It Notes had been placed on the regulatory wall, but all the cracks had only been cleaned, not even whitewashed, to look more presentable.
The use of Airworthiness Reviews fell at their first attempt when that aircraft failed the very first AR question (it did not have a valid Maintenance Programme) but this was ignored by a certain Eng O and stated as a Pass! (I again assumed that this Eng O was chasing a promotion rather than proving a system worked)
As for training standards, there are now serving technicians with EASA Part 66 licences to allow them to work on A330, A400, G500, Beech350 and the like. Also, I believe the Cosford syllabus is similar to EASA standards, probably because MOD can't staff its own full training syllabus. Finally, the EU Mil Airworthiness Regs (EMARs) also cover technician training so there may be some input there too.
I have just observed my own statement, above, and realised how the civil aircraft types mentioned reflect how the EMAR systems may move toward in the future. With a clear difference between 'Airworthiness' (as apparently governed by the needs of EASA and civilian licensing of maintenance techs) and 'Role Equipment' which I define as those systems which do not have a direct effect on the aircraft's ability to maintain flight and land under control.
Food for thought.
Food for thought.
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We were advised (by legal qualified officers) that in the event of an accident and consequential court action, any safety determination we had made could be expected to be investigated by the likes of the HSE or courts to establish whether the legal criteria had been met. Key to that would be questioning in court to examine whether the hazards had been eliminated or mitigated to the degree mandated by the Act. The MAA is quite right; as a matter of law its what the court determines that matters - the criterion exists for the courts to apply. The legal eagles did try to prevent our use of the ALARP term odd times in case it annoyed the courts.
EAP
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Its worth noting that the UK took a very strong part in the process of developing the EMARs. The various tasks were separated into four multi-State Task Forces, two of which were chaired by UK MAA staff, the other two being chaired by Italy and France. I think its no secret that the MAA used the EMARs to develop new regulatory arrangements rather than developing UK only approaches. For example, refresh of the DAOS regs was delayed until EMAR 21 was completed. EMAR 66 was also regarded that way but was proving tricky to implement - I've lost touch so it might be there now.
If anyone is interested, the MAWA website can be found here: https://www.eda.europa.eu/experts/airworthiness
EAP
EAP86, Rigga, et al
Many Thanks.
Haddon-Cave confirmed the real problem is implementation. He didn't uncover this, he was just pointed to directives that staff should NOT implement them, but falsely declare they had. That, surely, is where the MAA should have been focusing attention.
Looking at at well over 70 deaths discussed here over the years, I can point straight to the 'old' regulations, set out in one Def Stan and one chapter of another, that, if implemented, would have avoided them. I can't identify the same conciseness in the MAA regs. To me, that means the MAA has gone down the wrong path. The Hawk XX177 accident rather proves the point.
I know the MAA set about auditing project teams when it was formed in 2010. But if this didn't reveal the invalid Hawk safety case and lack of basic audit trail, then it didn't ask the right questions.
Many Thanks.
Haddon-Cave confirmed the real problem is implementation. He didn't uncover this, he was just pointed to directives that staff should NOT implement them, but falsely declare they had. That, surely, is where the MAA should have been focusing attention.
Looking at at well over 70 deaths discussed here over the years, I can point straight to the 'old' regulations, set out in one Def Stan and one chapter of another, that, if implemented, would have avoided them. I can't identify the same conciseness in the MAA regs. To me, that means the MAA has gone down the wrong path. The Hawk XX177 accident rather proves the point.
I know the MAA set about auditing project teams when it was formed in 2010. But if this didn't reveal the invalid Hawk safety case and lack of basic audit trail, then it didn't ask the right questions.
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To be fair to the MAA they did establish their plans early on, structuring them as 10 separate workstreams and I believe the implementation issue was a serious driver. The creation of the Duty Holder construct was an attempt to establish clear obligations for those charged with the responsibility for the various aspects of military aviation safety to improve implementation.
As regards the regs/EMAR aspect, I think they also recognised that the existing regs had developed over the years in a higgledy piggledy fashion and were somewhat lacking. Courts tend to recognise the civil regs as a sort of 'gold standard' and basing future regs on the civil approach was a shrewd move. Harmonisation of the regs across the various National approaches in Europe also tended to enhance the regs' status in the eyes of Courts (we're following International best practice etc...) and shared the rule making task across a larger number of competent people. Note that the UK wasn't the only Nation worrying that their regulatory arrangements were not fit for purpose, faults having been brought to light by the findings following fatal accidents.
Without going into details, I believe that the MAA's audits did find issues within the PTs but they accepted that efforts to correct the failings were in progress so further time for compliance was granted. Some issues will take quite a time to fix but I've been away from the sharp end for some years and I have no feel for the current state of play.
EAP
As regards the regs/EMAR aspect, I think they also recognised that the existing regs had developed over the years in a higgledy piggledy fashion and were somewhat lacking. Courts tend to recognise the civil regs as a sort of 'gold standard' and basing future regs on the civil approach was a shrewd move. Harmonisation of the regs across the various National approaches in Europe also tended to enhance the regs' status in the eyes of Courts (we're following International best practice etc...) and shared the rule making task across a larger number of competent people. Note that the UK wasn't the only Nation worrying that their regulatory arrangements were not fit for purpose, faults having been brought to light by the findings following fatal accidents.
Without going into details, I believe that the MAA's audits did find issues within the PTs but they accepted that efforts to correct the failings were in progress so further time for compliance was granted. Some issues will take quite a time to fix but I've been away from the sharp end for some years and I have no feel for the current state of play.
EAP
I haven’t flown a Hawk for a long time, but how do you propose “showing someone that the pin is in the seat”? By definition the pin is fitted to the seat pan handle and therefore can’t be seen easily from outside..
Certainly on my own fleet the pin is shown to the ground crew prior to taxy, then inserted into the stowage which is below the cockpit sides.
Certainly on my own fleet the pin is shown to the ground crew prior to taxy, then inserted into the stowage which is below the cockpit sides.
What I meant is that the seat pin should be left in place after landing, IN ITS FLIGHT STOWAGE until the pan is reached, engine shutdown and then carefully replaced with visual observation, by the occupant, of correct insertion, NOT doing it by feel during taxi in when eyes should be outside particularly with other aircraft in close proximity.
That’s the way it was done during my time 12 years on ejection seats and I still feel it is the safer and better procedure.
That was on mk2, 3 & 4 seats so perhaps there are good reasons, no one has yet explained, that the Mk10 has to be different.