The Nimrod Review - Official Documents

Chapter 19 – Shortcomings of Current System
renamed “Letters of Authority” to make it crystal clear that responsibility for safety remains at, and is driven
from, the very top, and what is being given is authority to act. Delegation is a two-way street, with reciprocal
duties and responsibilities between the delegator and delegatee
(18) There is a lack of alignment of duty, responsibility, resources and expertise.
19.22
The current safety system operating in the MOD is illogical and dysfunctional because duty, responsibility,
resources and expertise are not aligned or in the same hands:
19.22.1
19.22.2
19.22.3
AOAs, namely Group and Base Commanders and Force HQ have: (a) the relevant knowledge of
operational requirements, problems, and priorities; (b) immediate and daily access to the views
and expertise of Front Line air and engineering crews; (c) the most direct interest in ensuring the
safety and airworthiness of their aircraft; and (d) overriding responsibility for the safety of the
personnel under their command. However, Base Commanders and Force HQ have: (i) no budget;
(ii) no direct access to the Design Authority; and (iii) no responsibility for platform safety and
airworthiness.
The Design Authority (BAE Systems) has: (a) the relevant design knowledge and expertise;
(b) ownership of the intellectual property; (c) increasing knowledge of and responsibility for
maintenance; and (d) substantial manpower and resources. But the Design Authority has: (i) no
funds save those negotiated on a piece-work rate with the IPT; and (ii) no overall responsibility for
the safety and airworthiness of aircraft which they manufactured and (increasingly) maintain.
The platform IPT has: (a) neither the operational nor the design knowledge or expertise nor the
manpower, in-house, to be able to deliver safety and airworthiness themselves; (b) no option
but to outsource much of the Safety Case work; (c) to meet the requirements and views of the
Operator; (d) conflicting roles as both regulator and provider of capability; and (e) a myriad of
other competing tasks. However, the IPT has delegated responsibility for platform safety and
Airworthiness on a day-to-day basis. IPTs are sometimes considered merely another layer of
bureaucracy.
(19) Operators have not taken charge of Airworthiness.
19.23
AOAs and Front Line operators should own airworthiness. They are most directly affected by the absence of
it. As emphasised by the Chairman and Managing Director of Conoco, however, “By and large, safety has to
be organized by those who are directly affected by the implications of failure”. 10 It is for this reason that Lord
Cullen said that the operators themselves needed to be involved in drafting their own Safety Cases. Currently,
everyone has been tending to look in the wrong direction i.e. towards DE&S and Industry for this task.
(20) There is a lack of corporate memory.
19.24
The diffuse Airworthiness structure, and absence of requirements for single, centrally-owned Databases,
Safety Cases, and Risk Registers, means that there is a lack of corporate memory. This is particularly worrying
in relation to legacy platforms. The older a platform becomes, the more important it is to gather and study
data on it.
(21) Reviews and inspections focus on process rather than product.
19.25
Airworthiness reviews and inspections tend to focus on confirming whether relevant processes are in
place, rather than investigating whether there is compliance and whether the processes are, in fact, having
the desired effect. There has been a lack of penetration in audits. Auditors have tended to chase ‘paper
10 Cited in the Cullen Report, paragraph 21.4.
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