The Nimrod Review - Official Documents

B. Clearly Identified Airworthiness ‘Duty Holders’
Current position
21.19
21.20
Chapter 21 – New Military Airworthiness Regime
Whilst the term ‘Duty Holder’ is liberally accorded to many in senior positions across the three Services and
in the Support domain, there is little clarity as to its precise meaning or who is ultimately accountable for
Airworthiness27 across the MOD.
The command chain often masks true Airworthiness accountability in AOAs. The chain of command
is used to manage the delivery of Capability throughout the ranks, from senior staff down to delivery at
Unit level. There is a complex set of interfaces within, and across, command chains which manage support
arrangements and undertake self-regulation activity. In the Maintenance domain, Quality Assurance is the
means by which self-regulation is carried out. In the Operational domain, Standards and Evaluation teams
(STANEVAL) check aircrew flying competencies. Neither mechanism provides comprehensive assurance,
independent or otherwise. Delegation of Airworthiness responsibility is clearly identifiable in the Acquisition
environment. The same is not true, however, in the AOAs, who use the equipment and who own the majority
of risks pertinent to maintaining the Airworthiness of the platform. It should be noted that, in the Nuclear
environment, specific safety responsibilities are identified with specific individuals.
Problems with the current position
21.21 The first major problem is a lack of clarity:
most people within the three Services would not be able to identify
the Duty Holders for Airworthiness, nor articulate their responsibilities. Even those that believe they are Duty
Holders disagree as to their respective Airworthiness responsibilities and degree of accountability. There is,
moreover, confusion with holders of Letters of Delegation.
21.22 The second major problem is lack of alignment:
responsibility, authority and financial control are not in the
same hands. Whilst Unit Commanders are responsible for: (a) the delivery of Capability; (b) the safe operation
of equipment; and (c) the safety of people on their Unit, they have little in the way of authority over the
Support infrastructure that serves them. Real power and authority lies, unsurprisingly, with those who have
and exert financial leverage elsewhere in the organisation. It is a fact of life that those who control the money
wield authority over those who depend on it.
21.23 The third major problem is a lack of a focal point:
there is no chief Airworthiness engineer, or senior engineers or
operators, who are the focal point and directly accountable for ensuring Airworthiness regulatory compliance
in the Operating domains.
21.24 The fourth major problem is that DE&S faces the wrong way:
DE&S Support organisations such as IPTs do not
face and serve those who are in fact responsible for Airworthiness, namely the Operators, but are inclined
rather to face towards those that hold the financial purse-strings. For instance, IPTs negotiate maintenance
contractual arrangements with approved organisations on behalf of the staff in the Commands who have the
money to pay for the service, rather than for the Duty Holders at the Operating bases who use the equipment
and who have a duty of care to their people.
21.25 The fifth major problem is the apparent schism in the consideration of airworthiness.
The DE&S focus is,
quite logically, very much on the airworthiness of equipment. The first Nimrod Safety Case was explicitly an
‘Equipment’ Safety Case, aimed at ensuring that the equipment presented to the Operators was airworthy.
The minutes of the Platform Safety Case Meetings focus very much on this aspect. The RAF, on the other
hand, has a long established and comprehensive system of ensuring that its aircrew operate an aircraft
safely and within defined limits (the key element of operational airworthiness). As an example, each year the
majority of aircrew are subject to a STANEVAL examination of their practical skills and theoretical knowledge.
However, what is missing to date is an all-encompassing system that acknowledges the inextricable links
between the many facets that contribute to Airworthiness. The best people to organise that system are
27 Airworthiness, JSP553 definition: “The ability of an aircraft or other airborne equipment or system to operate without significant hazard to aircrew,
ground crew, passengers (where relevant) or to the general public over which such airborne systems are flown.”
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