Self Regulation Does Not Work, and in Aviation it Kills!
Thread Starter
Self Regulation Does Not Work, and in Aviation it Kills!
Self Regulation Does Not Work, and in Aviation it Kills! (c) Chugalug2
This is an intent that Chug/Tuc always press with and so I thought I would do some Sunday morning research:
UK MILITARY SAFETY
The Ministry of Defence (a Govt Dept) uses the following to safely regulate its activities:
Defence Accident Investigation Branch (Defence AIB)
Defence Fire Safety Regulator (DFSR)
Defence Land Safety Regulator (DLSR)
Defence Maritime Regulator (DMR)
Defence Nuclear Safety Regulator (DNSR)
Defence Ordnance, Munitions and Explosives (OME) Safety Regulator (DOSR)
Military Aviation Authority (MAA)
Headquarters Policy (HQ-Pol)
UK CIVILIAN TRANSPORT SAFETY
The Department for Transport uses the following to safely regulate its activities:
Office of Rail and Road
Driver Vehicle and Licencing Agency (DVLA)
Driver and Vehicle Standards Agency (DVSA)
Maritime and Coastguard Agency (MCA)
British Transport Police Authority
National Lighthouse Board
Transport Commissioners
Civil Aviation Authority (CAA)
Highways England
Air Accident Investigation Branch (AAIB)
Rail Accident Investigation Branch (RAIB)
Maritime Accident Investigation Branch (MAIB)
HIGH LEVEL REGULATORY OVERSIGHT OF BOTH DEPARTMENTS
Both of these are overseen by the Government Legal Department (GLD) to ensure that UK Law is upheld. The GLD are a part of the Treasury and is headed by a Senior Civil Servant. The Health and Safety Executive (HSE) have UK Legal jurisdiction over all Govt Depts and have enacted their right of Crown Censure in recent times on the MOD - Brecon Beacons deaths and the crushing of driver at MOD Kineton. Moreover they were given primacy on the Red Arrows ejection seat accident. Then, when there is a death or serious injury, there is the Coroner to answer to. So the only 'Self Regulation' I can see is that the Government effectively regulates its own activity. But then who would check the Government? Well the electorate every 5 years or so.
So, this leads me to think that there is no sense in the 'self regulation' comment and that this is misleading? If it is meant that regulation should not be within that particular Govt Dept then we would need to deconstruct all Govt Depts as they all regulate within but with a level of cross-Dept oversight. Is that a fair assessment given the facts above, or am I missing something?
LJ
This is an intent that Chug/Tuc always press with and so I thought I would do some Sunday morning research:
UK MILITARY SAFETY
The Ministry of Defence (a Govt Dept) uses the following to safely regulate its activities:
Defence Accident Investigation Branch (Defence AIB)
Defence Fire Safety Regulator (DFSR)
Defence Land Safety Regulator (DLSR)
Defence Maritime Regulator (DMR)
Defence Nuclear Safety Regulator (DNSR)
Defence Ordnance, Munitions and Explosives (OME) Safety Regulator (DOSR)
Military Aviation Authority (MAA)
Headquarters Policy (HQ-Pol)
UK CIVILIAN TRANSPORT SAFETY
The Department for Transport uses the following to safely regulate its activities:
Office of Rail and Road
Driver Vehicle and Licencing Agency (DVLA)
Driver and Vehicle Standards Agency (DVSA)
Maritime and Coastguard Agency (MCA)
British Transport Police Authority
National Lighthouse Board
Transport Commissioners
Civil Aviation Authority (CAA)
Highways England
Air Accident Investigation Branch (AAIB)
Rail Accident Investigation Branch (RAIB)
Maritime Accident Investigation Branch (MAIB)
HIGH LEVEL REGULATORY OVERSIGHT OF BOTH DEPARTMENTS
Both of these are overseen by the Government Legal Department (GLD) to ensure that UK Law is upheld. The GLD are a part of the Treasury and is headed by a Senior Civil Servant. The Health and Safety Executive (HSE) have UK Legal jurisdiction over all Govt Depts and have enacted their right of Crown Censure in recent times on the MOD - Brecon Beacons deaths and the crushing of driver at MOD Kineton. Moreover they were given primacy on the Red Arrows ejection seat accident. Then, when there is a death or serious injury, there is the Coroner to answer to. So the only 'Self Regulation' I can see is that the Government effectively regulates its own activity. But then who would check the Government? Well the electorate every 5 years or so.
So, this leads me to think that there is no sense in the 'self regulation' comment and that this is misleading? If it is meant that regulation should not be within that particular Govt Dept then we would need to deconstruct all Govt Depts as they all regulate within but with a level of cross-Dept oversight. Is that a fair assessment given the facts above, or am I missing something?
LJ
Leon
Having headed the thread “...Aviation”, you list a number of entities who are mostly unconcerned. But your point is taken.
Irrefutable facts:
This, and natural justice, makes it unsafe for MoD to sit in judgement of itself. The fact that MoD continues to make – in fact actively demands, under threat of sanction – the same old mistakes, means, I believe, that it is time to try something different. And legal.
Of those you list involved in aviation, the Air Accidents Investigation Branch are the full-time professionals. The MoD departments are, at best, enthusiastic amateurs, most there on a 2 year desk job they see as a route to advancement. A possible solution emerges.
You cite the HSE having primacy on the Red Arrows XX177 accident, but they only got seriously involved after the CPS conducted a disgracefully narrow “investigation”, limiting its investigation to servicing of the equipment. The CPS has form here, including lying about lack of witnesses coming forward on Nimrod XV230. The case is sub judice, and it is to be hoped that the Crown Court, unlike the CPS and HSE, actually pays attention to the evidence. Perhaps, if justice is served and the MoD replaces Martin Baker in the dock, your question may receive more attention!
Having headed the thread “...Aviation”, you list a number of entities who are mostly unconcerned. But your point is taken.
Irrefutable facts:
- Many Government Ministers of all persuasions, Senior Officers/Officials and Cabinet Secretaries, have formally ruled that it is an offence to disobey an order to make a false declaration on airworthiness (and financial probity). The MAA has existed for seven years and has not sought to overturn these rulings – in fact, DE&S actually named a senior MAA officer in its last briefing to Minister, when it advised him to continue upholding the ruling. Which he did. In the past, some have queried this statement, but I assume that my having published the References, and MoD approved their publication, means it is now accepted.
- On 17 January 2011, Minister for the Armed Forces Nick Harvey confirmed that, under SDSR 2010, various MoD departments had demanded a substantial cut in airworthinesss funding. This, shortly after publication of the Nimrod Review and formation of the MAA. Clearly, MoD still retains a culture whereby such “savings at the expense of safety” are still acceptable, even after the Nimrod Review. As of that date, this was being fought by other parts of MoD (well done). Subsequent events, such as (but not restricted to) (a) the MAA condoning no safety case for the Hawk ejection seat, and an invalid one for the aircraft itself, and, similarly, (b) the Air Cadet saga, again involving unairworthy aircraft and no valid safety case, means that these demands were, at least in part, met. Or, perhaps, the “good” part of MoD succeeded in maintaining the status quo, which would actually be a huge setback, given the regression need to fix the failings noted by so many since the late 80s, and simply repeated by Haddon-Cave.
This, and natural justice, makes it unsafe for MoD to sit in judgement of itself. The fact that MoD continues to make – in fact actively demands, under threat of sanction – the same old mistakes, means, I believe, that it is time to try something different. And legal.
Of those you list involved in aviation, the Air Accidents Investigation Branch are the full-time professionals. The MoD departments are, at best, enthusiastic amateurs, most there on a 2 year desk job they see as a route to advancement. A possible solution emerges.
You cite the HSE having primacy on the Red Arrows XX177 accident, but they only got seriously involved after the CPS conducted a disgracefully narrow “investigation”, limiting its investigation to servicing of the equipment. The CPS has form here, including lying about lack of witnesses coming forward on Nimrod XV230. The case is sub judice, and it is to be hoped that the Crown Court, unlike the CPS and HSE, actually pays attention to the evidence. Perhaps, if justice is served and the MoD replaces Martin Baker in the dock, your question may receive more attention!
LJ, I see it much the same way as yourself. Where I do tip my hat to Tuc & Chug is that the MAA and MilAAIB draw all of their uniformed staff from the area under investigation and then return said staff to the area of investigation either at tourex or end of temporary detachment. In this regard the MoD aviation safety organisation is unique and it probably has a deleterious effect.
Could it be better - I believe so and have raised this point with 2 different MAA heads. The alternative structure I offered is to more closely mirror the AAIB who draw permanent staff from civil aviation. The MilAAIB should similarly draw permanent staff from military aviation (ideally FTRS) and (given the airspace is inherently a civilian/military mix) should report jointly to both Secretaries of State.
Unfortunately nobody made me Emperor so the status quo remains.
Could it be better - I believe so and have raised this point with 2 different MAA heads. The alternative structure I offered is to more closely mirror the AAIB who draw permanent staff from civil aviation. The MilAAIB should similarly draw permanent staff from military aviation (ideally FTRS) and (given the airspace is inherently a civilian/military mix) should report jointly to both Secretaries of State.
Unfortunately nobody made me Emperor so the status quo remains.
JTO
In other words, you agree with me!
MoD is long past the stage where it can appoint its own permanent staff in sufficient numbers. By definition, the vast majority were civilians, but the decision to close most workshops meant it no longer had a recruiting ground. I was speaking to an airworthiness certification engineer yesterday, and he wouldn’t get out of bed for what MoD offers the inexperienced staff who have replaced highly trained engineers. This is not to the MAA’s fault – they inherited this situation. Like you, I’ve made representations - our 3 Star (Mr Gould) didn’t bother to reply in January 2000. Perhaps because his immediate subordinate, the Nimrod/Chinook 2 Star, had just ruled that safety was optional, and one could sign to say the regs had been met, knowing they hadn’t. (Which is what prompted my submission to him).
The MAA cannot make inroads into this culture, and I’m not sure it wants to or even understands. Remember, MoD continues to confirm that not a single person in the MAA reported the systemic failings. That means; if they were trained, they avoided a legal obligation; if untrained, they aren’t suitably qualified or experienced. Some in the MAA might choose to challenge this; if so, take it up with your Air Policy branch and DE&S Secretariat, who wrote the letters with the agreement of your bosses. (Not too far from your own experiences, JTO).
As ever, I acknowledge the vast majority in MoD loathe this culture. Some years ago we speculated here that a high profile court case might do the business. We got the timid Nimrod Review, which MoD now rejects. Perhaps the XX177 case might be the catalyst. Come on Mr Campbell, tell the truth on behalf of your client.
In other words, you agree with me!
MoD is long past the stage where it can appoint its own permanent staff in sufficient numbers. By definition, the vast majority were civilians, but the decision to close most workshops meant it no longer had a recruiting ground. I was speaking to an airworthiness certification engineer yesterday, and he wouldn’t get out of bed for what MoD offers the inexperienced staff who have replaced highly trained engineers. This is not to the MAA’s fault – they inherited this situation. Like you, I’ve made representations - our 3 Star (Mr Gould) didn’t bother to reply in January 2000. Perhaps because his immediate subordinate, the Nimrod/Chinook 2 Star, had just ruled that safety was optional, and one could sign to say the regs had been met, knowing they hadn’t. (Which is what prompted my submission to him).
The MAA cannot make inroads into this culture, and I’m not sure it wants to or even understands. Remember, MoD continues to confirm that not a single person in the MAA reported the systemic failings. That means; if they were trained, they avoided a legal obligation; if untrained, they aren’t suitably qualified or experienced. Some in the MAA might choose to challenge this; if so, take it up with your Air Policy branch and DE&S Secretariat, who wrote the letters with the agreement of your bosses. (Not too far from your own experiences, JTO).
As ever, I acknowledge the vast majority in MoD loathe this culture. Some years ago we speculated here that a high profile court case might do the business. We got the timid Nimrod Review, which MoD now rejects. Perhaps the XX177 case might be the catalyst. Come on Mr Campbell, tell the truth on behalf of your client.
Thread Starter
Ancient Aviator
"Quis custodiet ipsos custodes?", indeed, who does watch the watchmen. It is ever thus and a difficult conundrum to solve.
Tuc/JTO, yup, I agree. But as AA62 has pointed out, who would you use? If the CPS and HSE can't be trusted then I guess we are kind of stuck with it? Whomever pays for any independent regulator is always at risk of accusations of bias or narrowing down the scope of their investigation. FTRS seems like a neat solition but still involves post sponsors and lines of funding - also, when it comes to renewal, then if the individual has been a difficult SOB then renewal may be unlikely. As for career inspectors like the AAIB then again this has pros and cons - yes you may get consistency, but you may also get staleness after 5-10 years in the same role; plus also, if you get a twonk in the post you may be stuck with them for aome time!
I think we should accept the current slight imperfections as it may be 'better the devil you know'?
LJ
"Quis custodiet ipsos custodes?", indeed, who does watch the watchmen. It is ever thus and a difficult conundrum to solve.
Tuc/JTO, yup, I agree. But as AA62 has pointed out, who would you use? If the CPS and HSE can't be trusted then I guess we are kind of stuck with it? Whomever pays for any independent regulator is always at risk of accusations of bias or narrowing down the scope of their investigation. FTRS seems like a neat solition but still involves post sponsors and lines of funding - also, when it comes to renewal, then if the individual has been a difficult SOB then renewal may be unlikely. As for career inspectors like the AAIB then again this has pros and cons - yes you may get consistency, but you may also get staleness after 5-10 years in the same role; plus also, if you get a twonk in the post you may be stuck with them for aome time!
I think we should accept the current slight imperfections as it may be 'better the devil you know'?
LJ
Leon
Again, points taken, but I can think of over 70 families who would prefer the "devil we know" to be in gaol. A "devil" may be just about acceptable if it could be guaranteed that he would not systematically breach his own mandated regulations, and then lie in court about it. MoD has proven itself, time and again, incapable. That is not a slight imperfection. That is a direct attack.
Again, points taken, but I can think of over 70 families who would prefer the "devil we know" to be in gaol. A "devil" may be just about acceptable if it could be guaranteed that he would not systematically breach his own mandated regulations, and then lie in court about it. MoD has proven itself, time and again, incapable. That is not a slight imperfection. That is a direct attack.
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Whilst this discussion is a little 'above' me, my personal experience of both military and civil flying anecdotally supports the original statement.
Certain companies actually falsified documentation in order to satisfy regulations (on several occasions).
Airlines that use 'Standard Weights' when we all knew they were wrong. I asked for a check weigh at Manchester once . . . - guess what.
When I flew with Biman Bangladesh there were appalling levels of incompetence, once more 'covered up' and even though I reported officially, it was still covered up.
I would love to believe 'Safety is our Prime Concern', my own experience doesn't support the assertion.
Certain companies actually falsified documentation in order to satisfy regulations (on several occasions).
Airlines that use 'Standard Weights' when we all knew they were wrong. I asked for a check weigh at Manchester once . . . - guess what.
When I flew with Biman Bangladesh there were appalling levels of incompetence, once more 'covered up' and even though I reported officially, it was still covered up.
I would love to believe 'Safety is our Prime Concern', my own experience doesn't support the assertion.
Thread Starter
but I can think of over 70 families who would prefer the "devil we know" to be in gaol. A "devil" may be just about acceptable if it could be guaranteed that he would not systematically breach his own mandated regulations, and then lie in court about it. MoD has proven itself, time and again, incapable. That is not a slight imperfection. That is a direct attack
Brian, I agree. There are some dreadful cover ups at all levels of civil aviation from General Aviation to Commercial Air Transport. Often the commercial edge is what instigates such bad behaviour especially if profit margins are low.
LJ
Leon, thank you for publicising my catch phrase. No charges levied and all are welcome to use it to spread the word! 
As tuc wisely says, best we stick to aviation without straying into yet other worlds such as those of the BMA or the Law Society. The main difference between the DfT and the MOD is that whereas the former is not an operator of any substance, the latter most certainly is via its Service subsidiaries. Thus the CAA can and does require every operator to conform to whatever it deems necessary, witness the extensive and costly list of kit and training following the 737 fire tragedy at Manchester. In contrast the MAA can't even accept that the chalice it was handed on its formation was a poisoned one, in that UK Military Airworthiness had been dealt a savage blow by the MOD in the "Golden Period" from which it is still reeling. Before it can begin to put it right it has to face up to that truth. Before it can do that it has to be free of the RAF High Command's continuing cover up of the actions of its VSOs in that Golden Period. To do that it has to be independent of the MOD. Ditto all of the above for the MilAAIB.
As to cost, the poor suffering British Taxpayer will have to bear it. He/she always does. As to the arrangements, keep it simple and sister the MAA with the CAA, likewise the MilAAIB with the AAIB. Both must be civilian led, both can be staffed by military personnel, preferably in new branches created for the purpose, as well as civilians. Expensive? Yes. Difficult? Certainly. But less expensive than the dysfunctional morass that we have today. There is a limit to how many fleets we can afford to ground or even pause. The rest must stay flying and the chronic and systemic unairworthiness purged from them. It will be a long job, hence the sooner we get started the better. Rather that than yet more heart breaking Airworthiness Related Fatal Air Accident threads started in this forum.
PS Apologies for the delay in posting. Mothers Day at Chug Towers!
As tuc wisely says, best we stick to aviation without straying into yet other worlds such as those of the BMA or the Law Society. The main difference between the DfT and the MOD is that whereas the former is not an operator of any substance, the latter most certainly is via its Service subsidiaries. Thus the CAA can and does require every operator to conform to whatever it deems necessary, witness the extensive and costly list of kit and training following the 737 fire tragedy at Manchester. In contrast the MAA can't even accept that the chalice it was handed on its formation was a poisoned one, in that UK Military Airworthiness had been dealt a savage blow by the MOD in the "Golden Period" from which it is still reeling. Before it can begin to put it right it has to face up to that truth. Before it can do that it has to be free of the RAF High Command's continuing cover up of the actions of its VSOs in that Golden Period. To do that it has to be independent of the MOD. Ditto all of the above for the MilAAIB.
As to cost, the poor suffering British Taxpayer will have to bear it. He/she always does. As to the arrangements, keep it simple and sister the MAA with the CAA, likewise the MilAAIB with the AAIB. Both must be civilian led, both can be staffed by military personnel, preferably in new branches created for the purpose, as well as civilians. Expensive? Yes. Difficult? Certainly. But less expensive than the dysfunctional morass that we have today. There is a limit to how many fleets we can afford to ground or even pause. The rest must stay flying and the chronic and systemic unairworthiness purged from them. It will be a long job, hence the sooner we get started the better. Rather that than yet more heart breaking Airworthiness Related Fatal Air Accident threads started in this forum.
PS Apologies for the delay in posting. Mothers Day at Chug Towers!
Thread Starter
Hi Chug, yes I had a short diversion in the middle of the day as well.
Now I really like the first bit but less the second bit. The problem with making the leadership all civvy is that personal agendas always come to bear when humans are involved. So I would suggest a 2-3 year rotational post between the CAA and MAA with the deputy always being cut from the other side's cloth. That would see independence. The UK AIRPROX Board kind of does what you suggest on a far smaller scale and I think that it would benefit from having a mix of CAA staff and uniformed MAA staff, possibly FTRS. If nothing else having the civvies investigate the military and the military investigating the civvies would see some neet cross-pollenation of ideas and best practice. Also, both sides could demonstrate further independence that seems to be required.
When you look at the Air Navigation Order, SERA and MAA Regulatory Publications then you see that they are pretty closely aligned. So to see a merger may not be that very difficult - as ever waivers and derogations will be needed for niche capabilities on both sides. Since the Shoreham accident the drafts of CAP403 and RA2335 have become very closely aligned and that shows what could be done. Maybe if the CAA leaves EASA due to BREXIT then a golden opportunity may present itself? (I know they have stated they do not intend to leave EASA but depending on where BREXIT takes us then we have no choice!).
LJ
As to the arrangements, keep it simple and sister the MAA with the CAA, likewise the MilAAIB with the AAIB. Both must be civilian led, both can be staffed by military personnel, preferably in new branches created for the purpose, as well as civilians.
When you look at the Air Navigation Order, SERA and MAA Regulatory Publications then you see that they are pretty closely aligned. So to see a merger may not be that very difficult - as ever waivers and derogations will be needed for niche capabilities on both sides. Since the Shoreham accident the drafts of CAP403 and RA2335 have become very closely aligned and that shows what could be done. Maybe if the CAA leaves EASA due to BREXIT then a golden opportunity may present itself? (I know they have stated they do not intend to leave EASA but depending on where BREXIT takes us then we have no choice!).
LJ
Leon, I do not think that the two would knit naturally together anyway at first. For a start the CAA is funded by the operators and licensees while the MAA would be funded by the government. On the other hand, a cross fertilisation of personnel and good practice between the two would ensure the return of much of the expertise and knowledge to Military Regulation so ruthlessly driven out of military airworthiness maintenance and provision.
As to who would be the DG, I'm afraid that the RAF has rather shot itself in the foot in that regard. Once its VSOs had targeted the Air Safety budgets, subverted the regs, and ordered subordinates to suborn them into the bargain, they have rather forfeited any expectation of being allowed the opportunity to repeat such pillage. You might respond that it was all some thirty odd years ago and times change, but as tuc reminds us it is still policy that such orders were acceptable and that disobeying them is still an offence. The cover up continues and hence perpetuates the crime.
Maybe in years to come an arrangement such as you propose might emerge after the reform we seek has changed hearts and minds. An important factor would be that the personnel should be semi permanent. A lot of the problems at the MOD seem to stem from the constant comings and goings into posts that require far more than 2-3 years experience. That is why I suggest the formation of a new Air Safety Branch so that whether you are civilian or Service, you understand the system intimately and thus would be aware of its fragility and the importance of preventing its subversion again.
Re the Regs, they never were the problem. All that was necessary was to implement them. That they weren't has cost some 70 lives accounted for in airworthiness related fatal air accident threads in this forum alone.
Finally, it's a bit rich to try to pin any blame on the Coroners for not bringing the MOD to heel. Other than telling the RAF that "There's something wrong with your bloody aircraft" or words to that effect, as famously stated by the Oxford Coroner, it is for the UK Military Air Regulator to ensure that it is not so. That it chose instead to mislead and dissemble to them instead is a comment on the MOD and not the Coroners!
As to who would be the DG, I'm afraid that the RAF has rather shot itself in the foot in that regard. Once its VSOs had targeted the Air Safety budgets, subverted the regs, and ordered subordinates to suborn them into the bargain, they have rather forfeited any expectation of being allowed the opportunity to repeat such pillage. You might respond that it was all some thirty odd years ago and times change, but as tuc reminds us it is still policy that such orders were acceptable and that disobeying them is still an offence. The cover up continues and hence perpetuates the crime.
Maybe in years to come an arrangement such as you propose might emerge after the reform we seek has changed hearts and minds. An important factor would be that the personnel should be semi permanent. A lot of the problems at the MOD seem to stem from the constant comings and goings into posts that require far more than 2-3 years experience. That is why I suggest the formation of a new Air Safety Branch so that whether you are civilian or Service, you understand the system intimately and thus would be aware of its fragility and the importance of preventing its subversion again.
Re the Regs, they never were the problem. All that was necessary was to implement them. That they weren't has cost some 70 lives accounted for in airworthiness related fatal air accident threads in this forum alone.
Finally, it's a bit rich to try to pin any blame on the Coroners for not bringing the MOD to heel. Other than telling the RAF that "There's something wrong with your bloody aircraft" or words to that effect, as famously stated by the Oxford Coroner, it is for the UK Military Air Regulator to ensure that it is not so. That it chose instead to mislead and dissemble to them instead is a comment on the MOD and not the Coroners!
Last edited by Chugalug2; 26th Mar 2017 at 22:21.
Be careful what you wish for......
After yet another crash of a perfectly serviceable helicopter being mishandled due to incorrect and illogical (negligent?) use of the autopilot, the CAA were embarrassingly forced to 'step-in' and mandate changes which were previously regarded as 'optional' by the operators.
Lest not forget the abuse of FDM data to allow flights and deterioration of MRGBs to continue.
Follow that with the political pressure applied by Hairbrush to get their grounded choppers flying again; until a repeat event exposed the shenanigans and spin for what it was.
Government/revenue collector and Oil companies' unhealthy relationship re slack use of 'best practice' and the number of 'blind eyes' present in authority, or at least where the Accountable Manager was meant to be seated......automation and performance 20-years behind fixed-wing despite operating to the same regulations.
Industry being asked if 'commercial pressure' had any affect upon 'safety' and the enquirer accepting the first answer they got as they didn't have the wherewithal to 'turn the stone over' and to have a good look.
The result:
Yet another Industry-quango was formed, employees paid by the oil operators and OEMs with the inevitable glossy brochures and proclamations quickly following on how everything was great again.
Next thing you read is industry media mis-reporting that everything is indeed 'safe' again - so get back in the chopper, sit down, strap-in and shut-up!
That's what happens in Civvy Street.
Lest not forget the abuse of FDM data to allow flights and deterioration of MRGBs to continue.
Follow that with the political pressure applied by Hairbrush to get their grounded choppers flying again; until a repeat event exposed the shenanigans and spin for what it was.
Government/revenue collector and Oil companies' unhealthy relationship re slack use of 'best practice' and the number of 'blind eyes' present in authority, or at least where the Accountable Manager was meant to be seated......automation and performance 20-years behind fixed-wing despite operating to the same regulations.
Industry being asked if 'commercial pressure' had any affect upon 'safety' and the enquirer accepting the first answer they got as they didn't have the wherewithal to 'turn the stone over' and to have a good look.
The result:
Yet another Industry-quango was formed, employees paid by the oil operators and OEMs with the inevitable glossy brochures and proclamations quickly following on how everything was great again.
Next thing you read is industry media mis-reporting that everything is indeed 'safe' again - so get back in the chopper, sit down, strap-in and shut-up!
That's what happens in Civvy Street.
EESDL, I am under no illusions that all will become a panacea under the reforms I call for. I well remember resenting the Dane Geld forever having to be forked out into the ever ravenous maw of the CAA, but as far as I know it has never set out to subvert its own mandated regulations. Of course the operators are always on its back to alleviate the financial and operational burden of conforming with those regulations. It is its job to insist that they be complied with. If it isn't doing that then start a campaign to force it to do so!
Civil Aviation does though have one great advantage over Military Aviation; the regulator, investigator and operators are separate and independent. In Military Aviation they are all one and the same.
Civil Aviation does though have one great advantage over Military Aviation; the regulator, investigator and operators are separate and independent. In Military Aviation they are all one and the same.
Then Military Aviation must be dire straits!
I left 11-years ago, not due to safety concerns but due to financial concerns and the fact that it was becoming obvious that there were not the funds to both fight a war and to and to provide the manpower and brainpower for such 'niceties'.
We were very much 'second-class citizens'
I left 11-years ago, not due to safety concerns but due to financial concerns and the fact that it was becoming obvious that there were not the funds to both fight a war and to and to provide the manpower and brainpower for such 'niceties'.
We were very much 'second-class citizens'
The DH staff are frequently exposed to intolerable issues that should have never been accepted by the PTs. The MAA expend their horsepower critiquing how quickly the DH staff can uncover the buried truth and the speed of the DH reaction to the seemingly endless crisis points. The PTLs and those with airworthiness responsibility appear to be flameproof and carry on photocopying their errors or misdeeds, typically with the MAA rep in the room who says nothing.
So why do I support the MAA - well with the one distinct exception it does have a structure and capability capable of ensuring airworthiness in a military environment. If the performance and actions of the MAA were critiqued as part of an independent MilAAIB investigation I am convinced that its emphasis would shift from ensuring that the DH or operators get the blame, to assuring that the MoD (including the MAA) is actually abiding to the standards that the SofS thinks he has set.
If and when major systemic failures are found during an incident or accident investigation the MAA staff, who through indifference, inaction or undue professional deference have failed in their duty, should be having sleepless nights. Authority without responsibility or accountability is having a deleterious effect on military airworthiness.
Perhaps the MAA would be more effective if it wasn't obsessed by trivia - every tiny problem seems to require a DASOR, especially the sort of thing that should just be an entry in a tech log or F700.
They must be drowning in useless and pointless data - none of which makes anything any safer - far from it, anyone who has been the 'victim' of an OSI or even lower level investigation will know that the 'just culture' turns into a witch-hunt and erodes trust between the 'four worlds' (God I hate that expression).
Eventually people stop reporting the sorts of things that do need to be reported and real problems get covered up in order to save face or avoid another pointless witch-hunt.
The MAA has turned into the manic cousin of HSE and it provides a horrible outlet for those career-types who revel in bringing others down or those that love spreadsheets, pie-charts and tick-boxes to show just how much safer they are than the 'other-guys'.
Add in all the other barriers to getting airborne - computer-based auths, on-line regulatory and planning documents and and endless stream of QCCs that HAVE to be met (and all of this stops working when Dii is upgraded) plus an ever increasing removal of trust in anyone to just do their job properly and you get a real Flight Safety problem since no-one is in their 'mission-bubble' any more when they walk for the aircraft.
They must be drowning in useless and pointless data - none of which makes anything any safer - far from it, anyone who has been the 'victim' of an OSI or even lower level investigation will know that the 'just culture' turns into a witch-hunt and erodes trust between the 'four worlds' (God I hate that expression).
Eventually people stop reporting the sorts of things that do need to be reported and real problems get covered up in order to save face or avoid another pointless witch-hunt.
The MAA has turned into the manic cousin of HSE and it provides a horrible outlet for those career-types who revel in bringing others down or those that love spreadsheets, pie-charts and tick-boxes to show just how much safer they are than the 'other-guys'.
Add in all the other barriers to getting airborne - computer-based auths, on-line regulatory and planning documents and and endless stream of QCCs that HAVE to be met (and all of this stops working when Dii is upgraded) plus an ever increasing removal of trust in anyone to just do their job properly and you get a real Flight Safety problem since no-one is in their 'mission-bubble' any more when they walk for the aircraft.
JTO, I disagree, as I still think we agree! The failings you (and crab) list are sufficient to warrant disbanding the MAA. It is unfit for purpose. I would be very much kinder if just one of its senior staff would speak out and admit why it exists. Instead, they lie.
A viable structure and capability has always existed. In most of the accidents we discuss, the system worked perfectly well until a few identifiable individuals broke the law. The system identified these breaches, but other identifiable individuals dismissed complaints with malice, and knowingly placed aircrew in danger. They did not intend to harm aircrew, but that was the predicted outcome. Some notifications were in general terms (e.g. Chinook - it isn't airworthy, you're prohibited from flying it); others very specific and deadly accurate (C130 XV179, Tornado ZG710, Nimrod XV230). Therefore, the knowledge that harm would be caused must have played a part in their decision making. In each case, it was cheaper, quicker and better to simply meet legal obligations.
None of that is in doubt. So why does the MAA continue to denigrate and deny?
So why do I support the MAA - well with the one distinct exception it does have a structure and capability capable of ensuring airworthiness in a military environment.
None of that is in doubt. So why does the MAA continue to denigrate and deny?
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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
Engines
Interestingly, on 28 November 2012 MoD’s Defence Equipment and Support Policy Secretariat distanced itself from the (previous) Government's acceptance of the Nimrod Review. This was after an MP pointed out to MoD that the MAA was not implementing Haddon-Cave's recommendations in full.
I think your item 5 important. You are of course correct. The "Operating" input should be limited to non-technical Service Deviations. (Technical ones already need to be written by engineering staff in the project team - a largely ignored reg). I think the VSOs' stance comes from the widespread failure to understand the difference between airworthiness and fitness for purpose. (And last time I spoke to a senior officers in the MAA, they didn't understand either). If you don't understand, you should not be involved.
MoD’s undertaking to implement Haddon-Cave ‘in full’
I think your item 5 important. You are of course correct. The "Operating" input should be limited to non-technical Service Deviations. (Technical ones already need to be written by engineering staff in the project team - a largely ignored reg). I think the VSOs' stance comes from the widespread failure to understand the difference between airworthiness and fitness for purpose. (And last time I spoke to a senior officers in the MAA, they didn't understand either). If you don't understand, you should not be involved.