The Nimrod Review - Official Documents

13.77
LOD
13.78
13.79
Chapter 13 – Cuts, Change, Dilution and Distraction (1998-2006)
complete the assessment prior to making any changes. Outcomes of assessment shall be included in
any submissions seeking endorsement to continue with the implementation phase. Once implemented
the impact of the changes shall be reviewed after an appropriate period.”
In my view, however, the absence of a formal regulatory requirement prior to 2006 did not mean that senior
officers and managers had no duty to carry out impact assessments in relation to changes initiated by them in
preceding years whenever appropriate. Common sense, good practice and responsible leadership have always
required that careful thought to be given to the impact of decisions potentially affecting safety, including
decisions giving rise to changes in organisational structures or resources which might affect safety.
As CDL, Sir Sam Cowan was ultimately responsible for safety and airworthiness in the DLO. Sir Sam Cowan
received an LOD direct from the Secretary of State. His LOD dated 27 April 1999 stated:
“As Chief of Defence Logistics you are granted delegated authority for ensuring the safety
and airworthiness of military aircraft, military aircraft materiel and services.... In executing
this delegated authority you are to ensure that all staff comply as appropriate with formally
promulgated procedures and regulations.
You may make further sub-delegations of this airworthiness to other MOD staffs who
are responsible for procurement of military aircraft, military aircraft materiel or services.
If you of those to whom you have delegated authority become aware of any practice or
procedure being followed in the procurement, support, or operation of military aircraft
materiel which may compromise airworthiness or safety standards, then you are to take
immediate steps to control the situation or, if outside your control, to draw the matter to my
attention and to the attention of the CDP and the Service Chief of the Staff concerned.”
Sir Sam Cowan delegated airworthiness authority to his 2-Star Director General of Operations & Business
Development (DG Ops & B Dev, including all Safety, Health, Environment and Fire Risk Management (SHEF). 32
But under his LOD, as CDL, he retained lead responsibility for safety and airworthiness.
Criticism of Sir Sam Cowan
13.80
13.81
13.82
In my judgment, in all the circumstances, it was incumbent on Sir Sam Cowan as CDL to carry out an overall
impact assessment before launching his ‘Strategic Goal’. The welter of ‘change’ which would inevitably
flow from implementation of his ‘Strategic Goal’ had obvious safety and airworthiness implications, both
directly and indirectly: directly, because a reduction in output costs of 20% over five years was plainly going
to drive cost-cutting measures which might affect safety and airworthiness; and indirectly, because the
major organisational changes envisaged and/or the sheer scale of activity in delivering change and ‘savings’
would inevitably divert time, attention and resources away from routine tasks such as to affect safety and
airworthiness.
Sir Sam Cowan did not carry out any initial impact assessment before picking his 20% figure or launching
his ‘Strategic Goal’. In my judgment, Sir Sam Cowan is open to criticism for not having done so. Good and
responsible leadership required it.
I am satisfied that, if he had given careful thought to the implications of imposing the ‘Strategic Goal’ on the
DLO at this time and some sort of impact assessment had been carried out, it would have been apparent,
at the very least, that the imposition of the blanket 20% ‘Strategic Goal’ gave rise to potentially significant
risks and great caution, sensitivity and vigilance would be called for to safeguard safety and airworthiness.
The following points, in particular, were foreseeable: (a) the difficulties that a large and complex organisation
such as the newly-formed DLO was bound to have at all levels in coping with such a major programme of
‘change’ and ‘transformation’; (b) the ‘Strategic Goal’ would drive a culture of cost-cutting which might be
at the expense of, and impact on, safety and airworthiness; (c) the difficulties of maintaining functional safety
and airworthiness oversight and standards when shifting from ‘functional’ to ‘project-based’ organisational
32 MOD Health & Safety Handbook, JSP375 Volume 1, October 2001.
375