The Nimrod Review - Official Documents

The Nimrod Review
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issues personal LODs to: (i) the Director of DARS (dual-hatted as Director MARSG); (ii) the Director of MAFTR
(dual-hatted as Director Air Systems) and (iii) to the Director of DAATM (dual-hatted as Dir Officer Battlespace
Management). 8 Both D MAFTR and D DAATM report to the MARSB through D MARSG. A new reporting and
analysis tool, the Aviation Safety Information Management System (ASIMS), is in the process of being trialled
and implemented. In addition, ACAS tasked DARS to examine Flight Safety in Afghanistan and Iraq and as
a result, a new post has been established for an in-theatre Flight Safety Officer to work across the various
command and international boundaries, deployed on 1 July 2009.
Shortcomings of present system
21.9
21.10
21.11
21.12
21.13
21.14
The MOD’s current Airworthiness system has largely evolved rather than been designed. Whilst the current
three-pillared ‘virtual’ military airworthiness authority represents a significant step in the right direction, it
is, in my view, too ethereal, disparate and weak for the job in hand. The function and identity of the three
Regulators is neither coherent nor optimally suited to the respective governance roles. The separate Release
to Service Authority (RTSA) edifice is an historical anomaly with little logic. Moreover, it is far from satisfactory
that ACAS should have to juggle his bi-furcated Lead Officer Airworthiness roles, as head of the ‘virtual’
Military Airworthiness Authority and head of the RAF RTS, with his many other important functions. Further,
it is both impractical and does not send out the right signals for the Head of Military Airworthiness to be
part-time, with real responsibility devolved to three specialist regulators and three RTSAs, comprising many
with dual-hats. Airworthiness is a full-time 24/7 job.
The current Regulators do not have the necessary oversight or authority over the AOAs or IPTs to govern
Airworthiness effectively. Unlike his CAA equivalent, the Air Equipment Regulator does not have sight of
occurrence reports, nor does he audit the Main, or Deployed, Operating Bases to assess either the standard of
maintenance or the aircraft themselves. Whilst the Flight Operations Regulator checks for process compliance
against the regulations that he issues, he does not undertake the ‘inspectorate of flight operations’ role at the
Front Line units that used to be carried out by the Inspectorate of Flight Safety (IFS). This IFS role was lost in
one of the more recent reorganisations. This was unfortunate because it had significant Airworthiness value.
The lack of oversight and authority over the AOAs, and lack of ‘presence’ at Operating Units, significantly
limits the ability of the Equipment and Flight Operations Regulators: (a) to shape policy and regulation on an
informed basis; (b) to gauge the effectiveness of it direction or ability; and (c) to impose coherence or provide
authoritative direction on Airworthiness matters.
The lack of efficacy and clarity of the current MOD Airworthiness system is in marked contrast, for example,
to the MOD Nuclear management arrangements whereby a 3/4-Star equivalent level committee (DNSC)
appointed by the Secretary of State defines, guides and issues Nuclear Safety policy, which is then ‘delivered’
via a 2-Star led DNSEB (effectively the Nuclear Regulator) via a limited ‘cascade’ of responsibility and inspected
for compliance on a regular basis by an independent, competent team. The DNSC is the authority through
which all related policy is written, issued and amended and through whom all occurrences/incidents are
reported.
The current, separate and variegated, Release to Service (RTS) arrangements are unsatisfactory. Airworthiness
should not be split into RTS and In-service. The three Services should not have materially different RTS systems,
employing as they do different skill sets and arrangements to maintain RTS independence. Moreover, the
arrangement whereby the Royal Navy and Army RTSAs are co-located with the respective AOAs casts doubt
over the degree of independence that they can provide or be seen to provide.
The current DE&S equipment Safety Management System (SMS) does not sufficiently recognise Airworthiness
as a discrete and separate field, requiring significant technical knowledge, expertise and experience. The
DE&S SMS encompasses far broader ‘Safety’ issues and risks than simply aircraft Airworthiness. Airworthiness
should not be rolled up with Safety generally. Further, the DE&S SMS is not recognised by Air AOAs who
manage their own Airworthiness risk separately and against quite different criteria.
Care needs to be taken in embracing all aspects of the civil model. The Air Equipment Regulator issues
approvals for industry design and maintenance support and interprets policy for the equipment and operating
8 D DAATM also supports ACAS in relation to European air traffic and airspace policy.