The Nimrod Review - Official Documents

Chapter 13 – Cuts, Change, Dilution and Distraction (1998-2006)
of equipment safety. This will best be prosecuted by the appointment of a 2* champion empowered by
the DESB”. 46 Commenting on the creation of DASC, Advantage said: “This initiative brings much closer
together the various components of air safety but does little, if anything, to move air safety closer in process,
procedure or organisation to the rest of the MoD safety world”. 47 The following criticisms and observations
by Advantage of the MOD airworthiness regime at the time are particularly relevant and noteworthy:
13.130.1 “IPTs do not believe that they get a sufficiently authoritative or sufficiently early view of who
needs to do what, and when it needs to be done, with regard to safety management.” (Major
Findings, page 4)
13.130.2 The IPTs, Operators and Maintainers of equipments and platforms in many cases have separate
Safety Management Systems which are sometimes disconnected and inconsistent.” (Major
Findings, page 4)
13.130.3 “Responsibilities for Safety Management are not clear through-life.” (Major Findings, page 4)
13.130.4 Section 2.2 of the report referred to the importance of separating the assurance functions from
the ensurance functions in order to maintain the impartiality and credibility of the assurance
provided. It was noted that “there is an inconsistent approach to this separation of assurance
and ensurance, and that this is further muddied by an unclear separation between advice and
assurance in some areas. These inconsistencies appear to be largely resource driven – by both
lack of and availability of resource – and this leads to different approaches being taken to,
for example, the use of Independent Safety Assurance (ISA). These differences are manifested
in different degrees of independence and also various interpretations of the “A” as meaning
advisors, assessors, assurers, auditors and also in different degrees of mandation of an ISA.
Taken together, these inconsistencies reduce the value of the assurance given to FSBs and the
DESB.” (paragraph 2.2.2)
13.130.5 Advantage thus recommended that a clear policy on the role and use of ISAs should be identified.
(paragraph 2.2.3)
By 2005 airworthiness regime convoluted, confused and ‘seemingly dysfunctional’
13.131
13.132
In its Joint Review of Airworthiness dated 10 January 2005, DASC itself reported:
“The MoDs aviation organisation is complex and as a result of successive organisational
changes (including increasing industrial involvement) the overlying structure of
airworthiness regulations and delegation of responsibility has become convoluted, is easily
misunderstood and displays a number of weaknesses.”
It was pointed out that there were now many departments developing aviation regulations, policy and advice
and “the airworthiness regime is open to misunderstanding in terms of “who is responsible for what?” unless
one has intimate knowledge of the subject”. 49 With admirable honesty, the DASC report concluded:
LOD chain confused
13.133
“As has been established, the overall picture of the airworthiness regime is perceived as
one of a wide range of interconnected agencies presenting a confusing and seemingly
dysfunctional whole”.
The lines of airworthiness delegation were no longer clear following the creation of the DLO. At one stage,
DG ES(Air) had LODs from the three Service Chiefs to delegate that authority from them to him to set the
policy and regulations across all military aircraft. Figure 13.5 is a rough diagrammatic estimation of the
position as it is recalled to have been.
46 Ibid, Summary, paragraph 10.
47 Ibid, paragraph 2.4.5.1.
48 Joint Review of Airworthiness by DASC dated 10 January 2005, DASC/5/8/9, paragraph 26.
49 George Baber’s written statement to the Review of 11 June 2009.
48
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