The Nimrod Review - Official Documents

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Chapter 21 – New Military Airworthiness Regime
It should be noted that the word ‘maintenance’ in HF (M)EMS is in brackets because, whilst the programme
is aimed initially at engineers, the technique of Error Management has a much wider applicability than just
engineering. This has been recognised with the advent of the Air Command HF (M)EMS programme and
particularly with visibility of the new Just Culture policy. If the RAF’s Air Command-led HF (M)EMS programme
is successful, there is potential to expand Error Management across the RAF, operations and engineering
environs , and then lose the (M). Beyond this, there is scope for a pan-Defence solution.
In my view, the (M)EMS initiative is a model of its kind, with huge potential benefits for the improvement of
Airworthiness management across the whole of Defence. I make Recommendations regarding it below.
Shortcomings of current position
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Whilst the collection of data to maintain the continued Airworthiness of the platform is required by JSP553,
there are no clear regulatory requirements for the format, content and compliance criteria for IPTs in the
management of maintenance data. Furthermore, IPTs are not required to demonstrate compliance to any
Regulator. This ‘free for all’ has encouraged divergent solutions, including outsourcing, and standards across
the IPTs (see above). Further, evidence suggests that several IPTs do not, in fact, undertake the required proactive
analysis of maintenance data. Of those who have outsourced the task, several IPTs are still unable to
provide evidence of detailed maintenance data analysis having been undertaken.
There is no overall role for the current Airworthiness Regulator in policing or co-ordinating mandatory reporting.
The recent ‘Can do Safely’ campaign initiated by Air Command in response to concerns on engineering
standards and practices at the operating bases was not initiated or governed by the MAR, who did not have
sight of the occurrence reports or the standard of the maintenance. Whilst Air Command is attempting to
tackle the symptoms of the problem in Forward, the strategic issues concerning the contractual arrangements
with Industry for several platforms have not been addressed by the current Regulator. A key problem is that
the contracts that have been implemented in Depth now mean that aircraft are not ‘reconditioned’ when
they undergo scheduled maintenance with a repair-to-fault strategy being adopted in its place. Further,
there is no longer the maintenance policy or resources to undertake ‘reconditioning’ maintenance in the
Forward domain with a cumulative deterioration in husbandry as a consequence. This situation would not
have occurred if the Airworthiness Regulator: (a) surveyed aircraft and maintenance at the operating bases;
(b) co-ordinated mandatory reporting; and (c) had the authority to mandate strategic change to support
arrangements for MOD aircraft. Further, several of the reporting systems for each of the Services differ in
format and intent and overlap, such that the potential benefits associated with a single Defence-wide system
are not realised. There are also numerous bodies involved in assimilating and processing data received who
cannot between them effect a coherent reporting system that stimulates and coordinates action from the
appropriate agency. Although the revised occurrence reporting system is now common across the Services,
there is still no single accountable action addressee. This means that key issues and trends could be missed if
they are not picked up by the appropriate addressee.
As set out above, HF (M)EMS has been recently been embraced by Air Command. Already used extensively
by Industry, and proven by the Army’s Apache Force, it provides a comprehensive, high volume reporting
system designed to pre-empt issues before they manifest themselves, and provides a ‘voice for all’ in the
organisation. (M)EMS aims to makes senior managers accountable whilst also ensuring that they have sight
of emerging issues before they become a serious problem. (M)EMS is an example of a laudable individual
initiative that one would expect the Regulator to be driving, but has been left to the Service operating
authorities to implement with potentially different levels of take-up across the Services.
DARS plays a major role in overseeing flight safety issues. This is, however, no single authority above to: (a)
provide comprehensive analysis and direction on the whole spectrum of Airworthiness issues; (b) interface
with the IPTs or the platform Risk Registers; (c) drive behind new Airworthiness and ‘best practice’ initiatives
gleaned from the civil sector and industry (such as (M)EMS above); and (d) provide the overall coherent,
measured and informed development of Airworthiness policy in response to reported incidents and trends
pan-Defence which is required. With no single authority responsible for monitoring mandatory reporting, the
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