Self Regulation Does Not Work, and in Aviation it Kills!
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Leon,
Thanks for starting what will be a really interesting thread for discussion and opinion. Here’s my attempt to help things along. When we talk about ‘self-regulation’, perhaps it might help to try to define what activities we think an ‘airworthiness regulator’ should do, and who should (or should not) be doing it.
1. First one’s obvious – to be the authority for all regulations, covering both operating and technical airworthiness. I think a high level MoD department should be doing this. Next is the job of setting up and running systems for reporting occurrences and events that bear on airworthiness. That includes providing independent oversight of the outputs. Again, I don’t think that having a two star led MoD Centre organisation doing that is a bad thing
2. Now a contentious one – assurance. Who audits the operation of the system to make sure that people are doing what they’re supposed to be doing? Again, I think that a two star led MoD centre department should be sufficiently separate from the DE&S and the Operating Commands to do be able to do this. Note that this aspect doesn’t include the next one:
3. Accident Investigation. I think this is one Haddon-Cave got it wrong. Conducting inquiries into accidents should be taken out of the MAA’s control and moved to a separate Government Agency, possibly reporting directly to the Secretary of State for Defence. This would allow inquiries to properly examine whether the MAA’s actions had a bearing. The MAAIB should be moved to the same location, but reporting separately to the SofS.
4. I’ve kept the contentious one until last. Haddon-Cave was clear that the role of RTSA should not be carried out by Service Commanders. He devoted a lot of space to arguing that the new MAA ‘Operating Airworthiness’ department should carry out the RTSA role. I agree that RTSA should be taken away from Service Commands – it’s here that some of the most egregious airworthiness failings (and cover ups) have taken place, with wholly inadequate and plain incorrect documents being used to put unsafe aircraft into service. The MoK Chinook was an example.
5. However I(and here I’m probably going to upset the pilots) I think it should go to the Technical area of the MAA, not the ‘Operating’ area as Haddon-Cave recommended. Preparation of an RTS is, in my view (a stand by for incoming) a systems engineering task. It uses the evidence developed by the technical processes of procurement to develop a safe and auditable set of limitations inside which the aircraft can be operated. It’s inextricably linked to the configuration of the aircraft. It’s a technical document, and should be owned and authorised by a technically competent person. At that stage, aircrew can take it for use.
6. Which brings me to my last point. Why didn’t the RTSA role go to the MAA as Haddon-Cave recommended? As I remember, there was a gap of around two years before the RA (1021) on RTSA came out, which confirmed that the role remained with ACAS for the RAF, ACNS(Pol) for the RN and ACGS for the Army. My guess – the RAF VSOs decided that this was the ditch they were going to die in. Looking at the RA, having the RTSA role held by the Service command chain makes little or no sense. The RA actually says that the RTSA is supposed to provide ‘Independent Air Safety assurance’ – some hope.
This is a direct contravention of the MoD’s undertaking to implement Haddon-Cave ‘in full’, and should be corrected.
So, that’s my put – comments? Best Regards as ever to all those who want the system to be better,
Engines
Thanks for starting what will be a really interesting thread for discussion and opinion. Here’s my attempt to help things along. When we talk about ‘self-regulation’, perhaps it might help to try to define what activities we think an ‘airworthiness regulator’ should do, and who should (or should not) be doing it.
1. First one’s obvious – to be the authority for all regulations, covering both operating and technical airworthiness. I think a high level MoD department should be doing this. Next is the job of setting up and running systems for reporting occurrences and events that bear on airworthiness. That includes providing independent oversight of the outputs. Again, I don’t think that having a two star led MoD Centre organisation doing that is a bad thing
2. Now a contentious one – assurance. Who audits the operation of the system to make sure that people are doing what they’re supposed to be doing? Again, I think that a two star led MoD centre department should be sufficiently separate from the DE&S and the Operating Commands to do be able to do this. Note that this aspect doesn’t include the next one:
3. Accident Investigation. I think this is one Haddon-Cave got it wrong. Conducting inquiries into accidents should be taken out of the MAA’s control and moved to a separate Government Agency, possibly reporting directly to the Secretary of State for Defence. This would allow inquiries to properly examine whether the MAA’s actions had a bearing. The MAAIB should be moved to the same location, but reporting separately to the SofS.
4. I’ve kept the contentious one until last. Haddon-Cave was clear that the role of RTSA should not be carried out by Service Commanders. He devoted a lot of space to arguing that the new MAA ‘Operating Airworthiness’ department should carry out the RTSA role. I agree that RTSA should be taken away from Service Commands – it’s here that some of the most egregious airworthiness failings (and cover ups) have taken place, with wholly inadequate and plain incorrect documents being used to put unsafe aircraft into service. The MoK Chinook was an example.
5. However I(and here I’m probably going to upset the pilots) I think it should go to the Technical area of the MAA, not the ‘Operating’ area as Haddon-Cave recommended. Preparation of an RTS is, in my view (a stand by for incoming) a systems engineering task. It uses the evidence developed by the technical processes of procurement to develop a safe and auditable set of limitations inside which the aircraft can be operated. It’s inextricably linked to the configuration of the aircraft. It’s a technical document, and should be owned and authorised by a technically competent person. At that stage, aircrew can take it for use.
6. Which brings me to my last point. Why didn’t the RTSA role go to the MAA as Haddon-Cave recommended? As I remember, there was a gap of around two years before the RA (1021) on RTSA came out, which confirmed that the role remained with ACAS for the RAF, ACNS(Pol) for the RN and ACGS for the Army. My guess – the RAF VSOs decided that this was the ditch they were going to die in. Looking at the RA, having the RTSA role held by the Service command chain makes little or no sense. The RA actually says that the RTSA is supposed to provide ‘Independent Air Safety assurance’ – some hope.
This is a direct contravention of the MoD’s undertaking to implement Haddon-Cave ‘in full’, and should be corrected.
So, that’s my put – comments? Best Regards as ever to all those who want the system to be better,
Engines
Lynxman:-
Just because the sign on the door (next to the one warning of Wet Paint!) includes the word "independent" doesn't mean it is. The Regulator and the Investigator do indeed come under the same DG and all are part of the MOD (ie the Operator). How is anything/anybody independent in that arrangement?
the Defence Accident Investigation Branch does not report to the MAA, it is an independent organization under DG DSA that can report directly to the SofS via DG DSA
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Lynxman,
Thanks for coming back. I'm afraid I think I may have to gently disagree with you here.
While the MilAAIB may now be under the direct line management of the DSA (a fairly recent development that corrected the utter nonsense of having an accident investigation team under an airworthiness regulator), it is the MAA who convenes an SI and appoints the President. During that investigation, the MilAAIB is an integral part of the "team" (SI + MilAAIB), which is headed by the President, who reports direct to D/ MAA. Therefore, the MAA potentially acquires control of MilAAIB activities during an investigation, which is the important part of their work. This functional link is not made entirely clear by MoD in its various websites.
There's also the fact that MilAAIB findings are incorporated into the MAA published report. This is an important point - the original RNAIU arrangements (which Haddon-Cave praised and recommended as a model) involved the President of a BoI requesting an AIU investigation. This investigation led to a separate AIU report, with findings and recommendations, which was submitted to the BoI president. The BoI then referred to the AIU report as it wished - but it couldn't edit the findings.
So, sorry, but I don't think the current arrangements provide a 'check' for item 3. In my view, accident inquiries need to be carried out by a department outside the MoD. I'd go further - the number of senior officers in the MilAAIB needs to be reduced. Certainly, the Head needs to be a suitably experienced and respected civilian.
But thanks again for coming back - and please feel free to continue to disagree - discussion and exchange of views is the only way to progress.
Best regards as ever to all those doing the investigations,
Engines
Thanks for coming back. I'm afraid I think I may have to gently disagree with you here.
While the MilAAIB may now be under the direct line management of the DSA (a fairly recent development that corrected the utter nonsense of having an accident investigation team under an airworthiness regulator), it is the MAA who convenes an SI and appoints the President. During that investigation, the MilAAIB is an integral part of the "team" (SI + MilAAIB), which is headed by the President, who reports direct to D/ MAA. Therefore, the MAA potentially acquires control of MilAAIB activities during an investigation, which is the important part of their work. This functional link is not made entirely clear by MoD in its various websites.
There's also the fact that MilAAIB findings are incorporated into the MAA published report. This is an important point - the original RNAIU arrangements (which Haddon-Cave praised and recommended as a model) involved the President of a BoI requesting an AIU investigation. This investigation led to a separate AIU report, with findings and recommendations, which was submitted to the BoI president. The BoI then referred to the AIU report as it wished - but it couldn't edit the findings.
So, sorry, but I don't think the current arrangements provide a 'check' for item 3. In my view, accident inquiries need to be carried out by a department outside the MoD. I'd go further - the number of senior officers in the MilAAIB needs to be reduced. Certainly, the Head needs to be a suitably experienced and respected civilian.
But thanks again for coming back - and please feel free to continue to disagree - discussion and exchange of views is the only way to progress.
Best regards as ever to all those doing the investigations,
Engines
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JTO: "Where I am not comfortable with is the attitude of the MAA by which it pushes issues back onto the Duty Holder chain whilst washing their hands. They don't even appear to have a moral compass let alone a duty of care to ensure that issues are resolved at the earliest practical level." I believe they do this because the legal duty of care for safety is mainly owned by the operators, hence the "Duty Holder" term (as an aside I think the term actually causes far more confusion than its worth). The MAA have expended considerable efforts trying to ensure that the operators understand their obligations.
Engines, point 3. At the time there was general surprise that CHC made recommendations around accident investigation at all since it wasn't seen as a particularly problematic area. The management chain aspect was always going to be a contentious issue but pragmatically speaking, I don't think its been a real issue (apart from one DG's obsession with a/c scaring horses being ridden by the public, allegedly :-))
Engines, points about the RTSA. I think the MAA had a few difficulties with how to fit the RTSA role into their proposed scheme of things at all. If the RTSA had moved into the MAA, I think the role would have disappeared within a few years purely because the complexity of modern in-service types tends to interfere with the more technical aspects of the RTSA role. Nevertheless the MAA probably could envisage that technical deviations have become necessary in some operational contexts, so the possibility remains. I might not be explaining this very well but I'm trying to avoid an essay on the subject. Its worth noting that it is very much in the operators' interests to own their own safety assurance function since they hold the duties so the RTSA role isn't a regulatory dead end.
I believe that when the new arrangements were becoming clearer, the MAA did take CHC through the differences from his recommendations to assure he was comfortable with them. I believe he refused to adopt a more formal role as this would have been in conflict with the independence demanded of his role as a Judge.
EAP
Engines, point 3. At the time there was general surprise that CHC made recommendations around accident investigation at all since it wasn't seen as a particularly problematic area. The management chain aspect was always going to be a contentious issue but pragmatically speaking, I don't think its been a real issue (apart from one DG's obsession with a/c scaring horses being ridden by the public, allegedly :-))
Engines, points about the RTSA. I think the MAA had a few difficulties with how to fit the RTSA role into their proposed scheme of things at all. If the RTSA had moved into the MAA, I think the role would have disappeared within a few years purely because the complexity of modern in-service types tends to interfere with the more technical aspects of the RTSA role. Nevertheless the MAA probably could envisage that technical deviations have become necessary in some operational contexts, so the possibility remains. I might not be explaining this very well but I'm trying to avoid an essay on the subject. Its worth noting that it is very much in the operators' interests to own their own safety assurance function since they hold the duties so the RTSA role isn't a regulatory dead end.
I believe that when the new arrangements were becoming clearer, the MAA did take CHC through the differences from his recommendations to assure he was comfortable with them. I believe he refused to adopt a more formal role as this would have been in conflict with the independence demanded of his role as a Judge.
EAP
Engines - whilst it may be the way of the modern world to have RTSA exclusively manned by engineers - that stops working when they make decisions about piloty things because they think they know better and won't ask an operator. That goes for aircraft configuration, role equipment, avionics and general ergonomic layouts of cockpits.
In order to free up aircrew, many aircrew posts within PTs and the like were gapped or removed so the aircrew input to many areas of airworthiness was lost.
As for the Duty Holder chain, we are constantly told that they are 'managing the risk' - this is nonsense, the people managing and dealing with the risk on a day to day basis are the crews but it gives upper management a warm and fuzzy feeling that they have taken responsibility.
As another example of how mad the world has become - colleagues and I who have been QHIs for many, many years now have to do the DTTT (defence train the trainers) course before we are deemed compliant with regulations. Accreditation was only provided in 2011 for the CFSH course and all of those who passed it - and instructed on it - before that time now have to lose a week of productive flying training to learn classroom skills that are wholly irrelevant to that flying training - just to keep the educators empire happy and tick some more 'safety' boxes. How did we ever manage to produce good quality aircrew without the extended INTROSH course?????
In order to free up aircrew, many aircrew posts within PTs and the like were gapped or removed so the aircrew input to many areas of airworthiness was lost.
As for the Duty Holder chain, we are constantly told that they are 'managing the risk' - this is nonsense, the people managing and dealing with the risk on a day to day basis are the crews but it gives upper management a warm and fuzzy feeling that they have taken responsibility.
As another example of how mad the world has become - colleagues and I who have been QHIs for many, many years now have to do the DTTT (defence train the trainers) course before we are deemed compliant with regulations. Accreditation was only provided in 2011 for the CFSH course and all of those who passed it - and instructed on it - before that time now have to lose a week of productive flying training to learn classroom skills that are wholly irrelevant to that flying training - just to keep the educators empire happy and tick some more 'safety' boxes. How did we ever manage to produce good quality aircrew without the extended INTROSH course?????
Whilst it may be the way of the modern world to have RTSA exclusively manned by engineers - that stops working when they make decisions about piloty things because they think they know better and won't ask an operator. That goes for aircraft configuration, role equipment, avionics and general ergonomic layouts of cockpits.
In 1999, the National Audit Office, and then Public Accounts Committee, published reports “Modifying Defence Equipment”. The NAO took on 7 test cases, two of which were programmes of mine. One of the questions it posed (it didn’t know the answer, so made no recommendation) was - why, when presented with precisely the same problem (relating to the issues you raise) do some projects crack them with effortless competence, and others (e.g. Nimrod, Chinook Mk3) immediately grind to a halt and waste billions? (By the way, this is the evidence that MoD and Government knew in 1999 these programmes were dying on their feet).
I was tasked with replying, initially to our 3 Star, Deputy Chief Executive of the Defence Procurement Agency, one David Gould. It was in 3 parts.
- I took a hypothetical test case, a proposed major modification/upgrade. I set out the process and procedures, and who was meant to what, and when. That’s simple, it’s a direct lift from a mandated Defence Standard, basic training notes, internal instructions, etc; all of which you must know backwards long before becoming a project manager.
- I then explained why and when all but one of the posts (and, hence the people) no longer existed. The only remaining one was the project manager. It followed that we no longer recruited project managers who knew the answer, which did not bode well.
- It was therefore a matter of luck if the project manager had done any of these jobs before, and was able to simply do his old job to maintain progress. I demonstrated that the successful projects among the 7 had such managers, the unsuccessful ones didn’t.
All very simple, but the 3 Star didn’t reply, and DPA’s official response was “We cocked up and it’ll never happen again”. A ludicrous response, when PE/DPA could not be held responsible for (e.g.) (a) the RN shutting down these posts, and (b) the RAF never having them in the first place (at least, not in living memory). That situation will, of course, be familiar to the few left in MoD who are familiar with this policy. (Which, because it is not resourced, is now only an aspiration).
Related to the general subject (airworthiness), this was the audit at which the Chief of Defence Procurement, in his evidence to the PAC in March 1999, admitted that the Chinook HC Mk2 was still not airworthy, almost 7 years after the Director of Flight Safety had warned the Chief Engineer and ACAS (who signs the RTS) of precisely the same thing. Had the Committees had their thinking hats on, they would have realised this immediately cleared the ZD576 pilots – as it did, 10 years later. Nothing in CDP's background suggested he knew anything about the subject. At the time, we thought it a subtle move by a sympathetic RAF or Army officer to slip that into his briefing, but nobody took the bait.
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EAP, Crab,
Thanks for coming back - you've raised some really useful points. I'd like to clarify a couple of things - my apologies for not being clearer in the first place.
First, accident investigation - Haddon-Cave's recommendations were a surprise. My guess is that he noted the differences between the RN and the RAF and thought that the RAF could do better. He may also have seen accident investigation as part of the safety management cycle, and this led him to recommend incorporating the new MilAAIB within the MAA. I thought this was an utter nonsense. It’s still not been properly fixed.
RTS and RTSA – this is an important area, and I’m honestly concerned at some of the comments here. Perhaps I can help.
In my view, the primary role of military aircraft engineer is to provide crews with available and effective aircraft and weapons. Safety and risk management are important, but are secondary. (Crab, I’m truly sorry to hear that this appears to have been forgotten in your area). It’s the engineers that ensure that aircraft are designed, built, modified and maintained so that the risk of them exploding, falling apart or otherwise catastrophically failing while carrying out their mission is acceptably low. They also ensure that the systems within it are working and are ‘fit for purpose’ – that is, they can be operated and used in a safe and effective way. All this can be rolled up into the term 'airworthy'.
The RTS is a key document and It’s absolutely vital that it’s supported by a thoroughly prepared Safety Case, and is 100% accurate. It's the key 'Certificate of Airworthiness' for the user to put the aircraft and crews into harm's way. It underpins documents such as the Aircrew manuals, FRCs and ODMs. It also authorises the use of service modifications, as it sets out the Service Deviations clearing those mods.
Building an RTS is the responsibility of engineers. But it has to be built with and for the user. For example, if a system doesn’t properly or reliably show its status, the RTS must contain limitations or warnings that allow the crew to manage that risk in the air. Those have to be developed with pilots at every stage. The process starts with test pilots, goes on with OEU crew and completes with aircrew working in the RTSA. It finishes with accurate and complete aircrew manuals, FRCs, ODMs, etc. I’ve built a few RTS, for fixed and rotary wing aircraft, dark and light blue. In every case, I made damn sure that anything ‘piloty’ in nature was built with and for ‘pilots’. Especially anything to do with ergonomics and system operation. Crab, any engineer who doesn’t do this needs a good kicking. Have at it. I certainly didn’t think I ‘knew better’ than aircrew.
One of the problems in the 90s was that the role and responsibilities of the RTSA had become diluted and confused during the many changes in the relevant publications. JSP553’s definition, which tried to fudge the differences between the RAF and the RN, was an utter disgrace. I think Haddon-Cave recognised this, and made an honest effort to put the system right by giving the job of preparing the RTS Request (RTSR) to the engineers in the PT, but leaving the job of issuing it to a separate and independent RTSA function in the ‘Operating’ area within the MAA.
I remain of the opinion that giving up the RTSA function was culturally unacceptable to RAF aircrew VSOs. To them, the job of issuing an aircraft ‘release’ could only be undertaken by senior aircrew. I’m sorry if this offends, but in my 25 odd years I saw many examples of RTS documents that were just poor. Poor beyond imagining. Poor to the point where they presented an obvious hazard to crews. All of these had been signed off by aircrew VSOs.
The argument presented in the MAA RA that the RTSAs “… shall provide the Duty Holder (DH) chain with independent Air Safety assurance…’ is, in my view, risible. They cannot be, in any normal sense of the word, considered independent. They’ve failed to do it for too many years at too high a cost in lives.
Best regards as ever to all those trying to do the right thing,
Engines
Thanks for coming back - you've raised some really useful points. I'd like to clarify a couple of things - my apologies for not being clearer in the first place.
First, accident investigation - Haddon-Cave's recommendations were a surprise. My guess is that he noted the differences between the RN and the RAF and thought that the RAF could do better. He may also have seen accident investigation as part of the safety management cycle, and this led him to recommend incorporating the new MilAAIB within the MAA. I thought this was an utter nonsense. It’s still not been properly fixed.
RTS and RTSA – this is an important area, and I’m honestly concerned at some of the comments here. Perhaps I can help.
In my view, the primary role of military aircraft engineer is to provide crews with available and effective aircraft and weapons. Safety and risk management are important, but are secondary. (Crab, I’m truly sorry to hear that this appears to have been forgotten in your area). It’s the engineers that ensure that aircraft are designed, built, modified and maintained so that the risk of them exploding, falling apart or otherwise catastrophically failing while carrying out their mission is acceptably low. They also ensure that the systems within it are working and are ‘fit for purpose’ – that is, they can be operated and used in a safe and effective way. All this can be rolled up into the term 'airworthy'.
The RTS is a key document and It’s absolutely vital that it’s supported by a thoroughly prepared Safety Case, and is 100% accurate. It's the key 'Certificate of Airworthiness' for the user to put the aircraft and crews into harm's way. It underpins documents such as the Aircrew manuals, FRCs and ODMs. It also authorises the use of service modifications, as it sets out the Service Deviations clearing those mods.
Building an RTS is the responsibility of engineers. But it has to be built with and for the user. For example, if a system doesn’t properly or reliably show its status, the RTS must contain limitations or warnings that allow the crew to manage that risk in the air. Those have to be developed with pilots at every stage. The process starts with test pilots, goes on with OEU crew and completes with aircrew working in the RTSA. It finishes with accurate and complete aircrew manuals, FRCs, ODMs, etc. I’ve built a few RTS, for fixed and rotary wing aircraft, dark and light blue. In every case, I made damn sure that anything ‘piloty’ in nature was built with and for ‘pilots’. Especially anything to do with ergonomics and system operation. Crab, any engineer who doesn’t do this needs a good kicking. Have at it. I certainly didn’t think I ‘knew better’ than aircrew.
One of the problems in the 90s was that the role and responsibilities of the RTSA had become diluted and confused during the many changes in the relevant publications. JSP553’s definition, which tried to fudge the differences between the RAF and the RN, was an utter disgrace. I think Haddon-Cave recognised this, and made an honest effort to put the system right by giving the job of preparing the RTS Request (RTSR) to the engineers in the PT, but leaving the job of issuing it to a separate and independent RTSA function in the ‘Operating’ area within the MAA.
I remain of the opinion that giving up the RTSA function was culturally unacceptable to RAF aircrew VSOs. To them, the job of issuing an aircraft ‘release’ could only be undertaken by senior aircrew. I’m sorry if this offends, but in my 25 odd years I saw many examples of RTS documents that were just poor. Poor beyond imagining. Poor to the point where they presented an obvious hazard to crews. All of these had been signed off by aircrew VSOs.
The argument presented in the MAA RA that the RTSAs “… shall provide the Duty Holder (DH) chain with independent Air Safety assurance…’ is, in my view, risible. They cannot be, in any normal sense of the word, considered independent. They’ve failed to do it for too many years at too high a cost in lives.
Best regards as ever to all those trying to do the right thing,
Engines
At the risk of being accused of blowing smoke...
Engines, if I may:
I think your last post is the best sub-1 page summary I have ever seen on the fundamental reasons behind the need for a proper role-relatable design process.
In particular, what "airworthiness" means in context. Also, the essential symbiotic relationship between pilots and engineers within the design & airworthiness domain is superbly well described.
When I am King, I'll put the contents of that post on the walls of every room and corridor in ABW (and, if truth be told, in a few Test Squadron and T&E engineers' offices as well.)
Smoke off, smoke off, GO!
Engines, if I may:
I think your last post is the best sub-1 page summary I have ever seen on the fundamental reasons behind the need for a proper role-relatable design process.
In particular, what "airworthiness" means in context. Also, the essential symbiotic relationship between pilots and engineers within the design & airworthiness domain is superbly well described.
When I am King, I'll put the contents of that post on the walls of every room and corridor in ABW (and, if truth be told, in a few Test Squadron and T&E engineers' offices as well.)
Smoke off, smoke off, GO!
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I would like to point out while you all think the CAA and EASA system Is impressive, it is far from it, it has become a overburdened bloatware driven by beurocrats whose main task appears to be to to generate legislation and paperwork which at the end of the day does nothing to increase safety nor productivity, increasing the legislative burden does not increase safety, it simply means those that play by the rules are penalised, while those that don't will not change simply because someone has stuck another layer of regulation on them.
The whole idea of EASA was to make a single playing field, however EASA of late on several issues have pushed it out to individual authorities to decide their course of actions, defeating the prime objective behind its existence, 8.33 radios being one of them.
As for the military conforming to airworthiness standards, well that has to be a none starter by their very operational requirements, I would love to see an airworthiness standard that covers BDR.
The whole idea of EASA was to make a single playing field, however EASA of late on several issues have pushed it out to individual authorities to decide their course of actions, defeating the prime objective behind its existence, 8.33 radios being one of them.
As for the military conforming to airworthiness standards, well that has to be a none starter by their very operational requirements, I would love to see an airworthiness standard that covers BDR.
Crab et al,
Unless things have changed, the role of the RTSA is equivocally not to mandate what goes on the aircraft. The platform Requirements Manager (aircrew type) is the custodian of what capability the aircraft has, and is responsible for corralling the relevant stakeholders to draft and endorse the URD/SRD. When the "trading" has happened and the kit purchased and mounted, the RTSA take the output of the ITEAP (V&V output, Safety Case and Boscombe flight test reports etc) and ensure the evidence points to the award of an RTS clearance. The role of the OEU is then to assure fitness for purpose. My increasing concern over the past decade has been the atrophy of such skills in the aircrew world, placing increased burden on others in the acquisition world. A career option for SQEP aircrew in acquisition / airworthiness would go an awful long way to solving our problems IMHO.....
Unless things have changed, the role of the RTSA is equivocally not to mandate what goes on the aircraft. The platform Requirements Manager (aircrew type) is the custodian of what capability the aircraft has, and is responsible for corralling the relevant stakeholders to draft and endorse the URD/SRD. When the "trading" has happened and the kit purchased and mounted, the RTSA take the output of the ITEAP (V&V output, Safety Case and Boscombe flight test reports etc) and ensure the evidence points to the award of an RTS clearance. The role of the OEU is then to assure fitness for purpose. My increasing concern over the past decade has been the atrophy of such skills in the aircrew world, placing increased burden on others in the acquisition world. A career option for SQEP aircrew in acquisition / airworthiness would go an awful long way to solving our problems IMHO.....
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There's a lot of detail in previous postings so I hope you won't mind if I generalise a little in response.
Any aerospace regulatory system, military or civil, exists to assure fitness for flight which is a property of the platform. Almost all definitions of 'airworthiness' are concerned with safety (fitness for flight) and they recognise that airworthiness is a property of the platform. The only western nation I'm aware of which brings fitness for purpose into its definition of airworthiness is Italy. I am not trying to say that fitness for purpose is not important or operationally essential, it's just that airworthiness (using my definition) has to come first. I have no problem with any relevant area of expertise having a contribution into the determination of airworthiness and I certainly include aircrew in this.
I do however have reservations with the current MAA approach to RTS regulation in that it is over-complex, suffers from a fair degree of duplication and seeks to involve all parties that have ever been involved historically with the production of the RTS irrespective of their competence or usefulness of contribution. Too much of the RTS process is driven by the organisational topology of the MOD and Service Operating Branches. To be fair to the MAA, they probably appreciated they were compromising matters but it was deemed necessary to obtain the buy-in of VSOs. My comments about RTSAs were in the context of how the contribution is made, not in the principle of taking aircrew inputs into account.
Much as Nutloose charges, I do admire the EASA regulatory system (the CAA's is hardly worth a mention as it is barely used) in that it seeks to place decision making in the hands of those competent to do so. Note that EASA didn't make the mistake of taking all powers to itself, something upon which the MAA is also to be congratuated. Nutloose seems to have issues with the implementation of the EASA system but without knowing more about the particulars, its hard to comment. I will say that regulation is a thankless task at the best of times as shown by the old term for the CAA, the Campaign Against Aviation.
I'm aware that under the pre-MAA regulatory regime George Baber actually tried to sort out a regulatory approach modelled on the authority structure of the EASA approach, working from first principles but adapted to the needs of the MOD. As you might imagine, that work probably wasn't given too much attention by the MAA; a pity as it could well have avoided some of the complexities of the current system.
EAP
Any aerospace regulatory system, military or civil, exists to assure fitness for flight which is a property of the platform. Almost all definitions of 'airworthiness' are concerned with safety (fitness for flight) and they recognise that airworthiness is a property of the platform. The only western nation I'm aware of which brings fitness for purpose into its definition of airworthiness is Italy. I am not trying to say that fitness for purpose is not important or operationally essential, it's just that airworthiness (using my definition) has to come first. I have no problem with any relevant area of expertise having a contribution into the determination of airworthiness and I certainly include aircrew in this.
I do however have reservations with the current MAA approach to RTS regulation in that it is over-complex, suffers from a fair degree of duplication and seeks to involve all parties that have ever been involved historically with the production of the RTS irrespective of their competence or usefulness of contribution. Too much of the RTS process is driven by the organisational topology of the MOD and Service Operating Branches. To be fair to the MAA, they probably appreciated they were compromising matters but it was deemed necessary to obtain the buy-in of VSOs. My comments about RTSAs were in the context of how the contribution is made, not in the principle of taking aircrew inputs into account.
Much as Nutloose charges, I do admire the EASA regulatory system (the CAA's is hardly worth a mention as it is barely used) in that it seeks to place decision making in the hands of those competent to do so. Note that EASA didn't make the mistake of taking all powers to itself, something upon which the MAA is also to be congratuated. Nutloose seems to have issues with the implementation of the EASA system but without knowing more about the particulars, its hard to comment. I will say that regulation is a thankless task at the best of times as shown by the old term for the CAA, the Campaign Against Aviation.
I'm aware that under the pre-MAA regulatory regime George Baber actually tried to sort out a regulatory approach modelled on the authority structure of the EASA approach, working from first principles but adapted to the needs of the MOD. As you might imagine, that work probably wasn't given too much attention by the MAA; a pity as it could well have avoided some of the complexities of the current system.
EAP
EAP86
I'm glad you said that about Gp Capt Baber. I've said all along that Haddon-Cave was an idiot for naming and shaming him. Baber actually deserved praise for recognising the safety case was poor (inevitable, given the 1993 policy to no longer fund their upkeep) and for letting a contract. That it was poorly managed is a separate matter.
Try telling the MAA that airworthiness precedes FFP! I did, and they told me I was wrong. If you get that wrong, it more or less follows that your entire approach and management structure will be wrong, leading to a misunderstanding about who does what, and who is responsible for the various parts of the Aircraft Document Set. I'd like to think they've changed their minds, but they haven't got round to changing the structure back.
I'm glad you said that about Gp Capt Baber. I've said all along that Haddon-Cave was an idiot for naming and shaming him. Baber actually deserved praise for recognising the safety case was poor (inevitable, given the 1993 policy to no longer fund their upkeep) and for letting a contract. That it was poorly managed is a separate matter.
Try telling the MAA that airworthiness precedes FFP! I did, and they told me I was wrong. If you get that wrong, it more or less follows that your entire approach and management structure will be wrong, leading to a misunderstanding about who does what, and who is responsible for the various parts of the Aircraft Document Set. I'd like to think they've changed their minds, but they haven't got round to changing the structure back.
Nutloose:-
Of the 70 deaths in airworthiness related fatal accidents discussed in this forum, only 10 were as a result of enemy action (Iraq Hercules), and it might be said that if the aircraft had been fit for purpose with ESF fitted even those could have been avoided. The real point of Military Airworthiness is force preservation, ie the aircraft and crews survive the peace so that they can get to war.
Of course war means that peacetime practice and regulation go out the window if the situation calls for it. I always instance Royal Marines clinging to the outside of two Apache's on a rescue mission. It's war, get over it! Eventually the paper work will follow, eventually the MAA will issue an exemption, or maybe not...
We've had the "military aviation is dangerous, you can't wrap it up in cotton wool" spiel in every airworthiness related thread on this forum. We never said you should. Just give the guys and girls a decent chance to get to the bloody war!
As for the military conforming to airworthiness standards, well that has to be a none starter by their very operational requirements, I would love to see an airworthiness standard that covers BDR.
Of course war means that peacetime practice and regulation go out the window if the situation calls for it. I always instance Royal Marines clinging to the outside of two Apache's on a rescue mission. It's war, get over it! Eventually the paper work will follow, eventually the MAA will issue an exemption, or maybe not...
We've had the "military aviation is dangerous, you can't wrap it up in cotton wool" spiel in every airworthiness related thread on this forum. We never said you should. Just give the guys and girls a decent chance to get to the bloody war!
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I understand that, and I heartily agree, what I was trying to get across is no matter how much you like to lessen the impact on crews from poor design and airworthiness failings, in a war situation the only way you can ensure zero deaths in the air due to failings in the aircraft or its defensive / offensive capability, is to stay on the ground.
The Jag used to have a BDR if I remember correctly that was a pre-drilled slab of ally that was screwed to the damaged wing, control rods were repaired with broom handles and jubilee clips, these are the things done in wartime to ensure it was a goer, ( Mind you, desperation came to mind ) hence the " I would love to see an airworthiness standard that covers BDR." in wartime you play by a different set of rules, you have too.
The Jag used to have a BDR if I remember correctly that was a pre-drilled slab of ally that was screwed to the damaged wing, control rods were repaired with broom handles and jubilee clips, these are the things done in wartime to ensure it was a goer, ( Mind you, desperation came to mind ) hence the " I would love to see an airworthiness standard that covers BDR." in wartime you play by a different set of rules, you have too.
It seems that we are in violent agreement then Nutty. All the airworthiness campaign is trying to do is to provide airworthy aircraft to aircrews that are kept airworthy and fit for purpose until first contact. After that it's mayhem of course, as you so rightly highlight.
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It was actually Air Commodore Baber by the time he was leading the MAA's predecessor. CHC had started his review exercise with a promise to name names if he found blame. I think he felt bound by that position when push came to shove.
I'm not sure which part of the MAA you were dealing with. I well remember sitting in a meeting around 3 years ago which was chaired by a MAA person where everyone (representing 10 or so european MAAs) was telling the Italian MAA equivalent that they had got it wrong. To be fair, during the first few years of the MAA's existence, I found most members had a reasonable appreciation of airworthiness principles.
As regards BDR, most military aviation takes place during peacetime so the emphasis on airworthiness is reasonable and cogent. I'm far from convinced that you can apply an airworthiness standard to BDR because its a discipline which only comes into play when the only meaningful standard is balancing operational necessity against the likelihood of fatality. For me the MAA have got this right; its not an area for regulation but it makes sense that the operators understand risk assessment and management so that their judgements can be defended if questions are asked.
EAP
It was actually Air Commodore Baber by the time he was leading the MAA's predecessor. CHC had started his review exercise with a promise to name names if he found blame. I think he felt bound by that position when push came to shove.
I'm not sure which part of the MAA you were dealing with. I well remember sitting in a meeting around 3 years ago which was chaired by a MAA person where everyone (representing 10 or so european MAAs) was telling the Italian MAA equivalent that they had got it wrong. To be fair, during the first few years of the MAA's existence, I found most members had a reasonable appreciation of airworthiness principles.
As regards BDR, most military aviation takes place during peacetime so the emphasis on airworthiness is reasonable and cogent. I'm far from convinced that you can apply an airworthiness standard to BDR because its a discipline which only comes into play when the only meaningful standard is balancing operational necessity against the likelihood of fatality. For me the MAA have got this right; its not an area for regulation but it makes sense that the operators understand risk assessment and management so that their judgements can be defended if questions are asked.
EAP
EAP86:-
And did so by naming officers of 1* and below, ie the usual MOD scapegoats. Strangely he didn't feel bound enough by his position to name the VSOs above those ranks who were really responsible for the UK Military Airworthiness scandal, and whose identities and actions he was very well aware of. Another MOD tradition...
CHC had started his review exercise with a promise to name names if he found blame. I think he felt bound by that position when push came to shove.
So why were these people, that had been so obviously neglegent, prosecuted?
whilst it may be the way of the modern world to have RTSA exclusively manned by engineers - that stops working when they make decisions about piloty things because they think they know better and won't ask an operator. That goes for aircraft configuration, role equipment, avionics and general ergonomic layouts of cockpits.
CHC had started his review exercise with a promise to name names if he found blame. I think he felt bound by that position when push came to shove.
To be fair, during the first few years of the MAA's existence, I found most members had a reasonable appreciation of airworthiness principles.
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Perhaps it would help things along if I focussed more on what could be done to improve the UK's military airworthiness. Alert - these are my opinions only, dissent is positively welcomed.
It struck me that we could take a look at how aircrew do their business - how do they achieve and maintain good standards of 'airmanship'? From my experience, it certainly included good clear rules. But far more important were good supervision and oversight. Plus really excellent training and a clear system for building experience. What they didn't do was rely on obeying their rules. I never met a pilot (or observer or aircrewman) whose proud boast was that they had submitted a 50 page document that proved that they were compliant with the latest set of rules. Nor did I ever encounter aircrew who said that they knew that they were safe because they always 'obeyed the rules'. God help me, I never heard aircrew justify a decision they'd made because 'you always have to think about how it would look in a Coroner's Court'.
We need to build a system that develops our young engineers in such a way that they get the information they need and build the experience they need, while getting the right level of supervision to stop them doing dumb stuff. We also need a better system of oversight (an engineers' equivalent of QFIs) to monitor what they are doing. How to do that? Well, my first stab would be to take some of the old Def Stand and recast them as 'Handbooks' - clearly setting out the key principles of airworthiness, and providing worked examples of how to achieve the right standards.
Next, I'd reinstate (in a modern form) the Modifications Committees, along with a recast version of the MF714/715 system (modification approval and progression forms) to help the PTs and other areas properly manage mods. I'd also make a rule that any acceptance of an aircraft, system, or modification would have to have a proper acceptance conference (along the lines of the old '555' system).
I'd also introduce a proper system of project reviews that brought in external reviewers to really 'scrub' the key stages, such as requirements approvals, V&V plans, and design reviews. (Incidentally, almost all aerospace companies already do these). In case you think I'm being overly bureaucratic about this, and just adding more layers of paperwork, here's what I saw happen over the past few years - this is happening on an aircraft near you right now....
1. Installing highly vulnerable civilian standard GPS systems in direct contravention of MoD policy
2. Deliberately disconnecting electrically operated weapon system from mandated safety switches
3. Failing to incorporate safety critical DA modifications for over three years (should have been done within 6 months). Then failing to record this failure on the Hazard Log
4. Failing to get expert advice from Dstl before specifying an all new INGPS primary navigation and flight control system. Result was an accuracy requirement less demanding than for an iPhone.
5. Installing a new radalt system with no (repeat, no) accuracy requirement
6. Letting the prime contractor decide what went in the SRD, and ignoring the warnings from the Requirements Manager
I'd help people get there by dismantling the runaway 'SQEP' empire that chews up man-hours, and restrict the MAA to one major update of each main RA series every 6 months.
Ok, I've doubtless bored enough people silly - any other suggestions?
Best Regards as ever to all those taking the time to get it right,
Engines
It struck me that we could take a look at how aircrew do their business - how do they achieve and maintain good standards of 'airmanship'? From my experience, it certainly included good clear rules. But far more important were good supervision and oversight. Plus really excellent training and a clear system for building experience. What they didn't do was rely on obeying their rules. I never met a pilot (or observer or aircrewman) whose proud boast was that they had submitted a 50 page document that proved that they were compliant with the latest set of rules. Nor did I ever encounter aircrew who said that they knew that they were safe because they always 'obeyed the rules'. God help me, I never heard aircrew justify a decision they'd made because 'you always have to think about how it would look in a Coroner's Court'.
We need to build a system that develops our young engineers in such a way that they get the information they need and build the experience they need, while getting the right level of supervision to stop them doing dumb stuff. We also need a better system of oversight (an engineers' equivalent of QFIs) to monitor what they are doing. How to do that? Well, my first stab would be to take some of the old Def Stand and recast them as 'Handbooks' - clearly setting out the key principles of airworthiness, and providing worked examples of how to achieve the right standards.
Next, I'd reinstate (in a modern form) the Modifications Committees, along with a recast version of the MF714/715 system (modification approval and progression forms) to help the PTs and other areas properly manage mods. I'd also make a rule that any acceptance of an aircraft, system, or modification would have to have a proper acceptance conference (along the lines of the old '555' system).
I'd also introduce a proper system of project reviews that brought in external reviewers to really 'scrub' the key stages, such as requirements approvals, V&V plans, and design reviews. (Incidentally, almost all aerospace companies already do these). In case you think I'm being overly bureaucratic about this, and just adding more layers of paperwork, here's what I saw happen over the past few years - this is happening on an aircraft near you right now....
1. Installing highly vulnerable civilian standard GPS systems in direct contravention of MoD policy
2. Deliberately disconnecting electrically operated weapon system from mandated safety switches
3. Failing to incorporate safety critical DA modifications for over three years (should have been done within 6 months). Then failing to record this failure on the Hazard Log
4. Failing to get expert advice from Dstl before specifying an all new INGPS primary navigation and flight control system. Result was an accuracy requirement less demanding than for an iPhone.
5. Installing a new radalt system with no (repeat, no) accuracy requirement
6. Letting the prime contractor decide what went in the SRD, and ignoring the warnings from the Requirements Manager
I'd help people get there by dismantling the runaway 'SQEP' empire that chews up man-hours, and restrict the MAA to one major update of each main RA series every 6 months.
Ok, I've doubtless bored enough people silly - any other suggestions?
Best Regards as ever to all those taking the time to get it right,
Engines
