The Nimrod Review - Official Documents

The Nimrod Review
21.80
21.81
Objectives
21.82
518
current system relies on many action addressees identifying issues that fall within their area of responsibility
with the real risk that issues are not adequately considered and that some risks may be missed.
In the civil model, all occurrence reporting is sent to the CAA which then distributes follow-up directives to
action addressees across the operating and equipment authorities and considers issuing guidance or policy
changes; this represents a logical and effective system.
Whilst Airworthiness is a sub-set of Safety, it requires specific and discrete management which can be diluted
by the more general ‘H&S’ approach, leading to a confusion of lines of accountability for Airworthiness and
Safety and an undermining of the process and technical needed to assure and ensure Airworthiness.
In order to underpin the authority and effectiveness of an MAA, four key objectives relating to data collection
and analysis need to be achieved:
Recommendations D
21.83
21.84
(1) The IPTs need to be able to predict maintenance failings by having in place systems for effective
data analysis to inform their support activity, maintenance policy and decision-making.
(2) The MAA needs to have a ‘closed loop’ which allows it to assess the effectiveness and consequence
of its regulations. The MAA needs to be the higher authority for a mandatory reporting system
which would provide it with feedback on the ‘health’ of military aircraft and their use, a part of
the Regulator’s oversight responsibility for Flight Safety. Such a system must cover the spectrum
of mandatory reporting topics. The Operating Centre Directors and the AOAs will be the action
addressees.
(3) There needs to be a fundamental change to the current reporting philosophy, not only to make
the MAA the higher authority for mandatory reporting, but also to stimulate the cultural change
that is needed to make the user community accountable to the MAA.
(4) The focus needs to move away from the reliance on merely ‘logging’ data and ‘fields of text’,
to a form which stimulates analysis and pro-active management to prevent the manifestation of
Airworthiness failings. The HF (M)EMS is but one example of methods which stimulate action in
preference to inert text or more regulation.
(5) Whilst there has been undoubted and commendable initial support for RAF HF (M)EMS, it is
important to ensure the initiative has the opportunity to realise its full potential for Defence.
In order to achieve these objectives, I make the following Recommendations:
Recommendation 21.D.1: All Maintenance Data Analysis shall be regulated.
For the avoidance of doubt, for Recommendation 21.D.1: (1) The Regulator shall devise, define and prescribe
standardised formats and contents for reporting and analysis and give direction on data management
processes to enable IPTs to meet their obligations for Continuing Airworthiness management; (2) The
Regulator shall consider whether, and if so where, such data changes may require contract amendment and
require all contractors to deliver data outputs which are ‘fit for purpose’ and which facilitate the pro-active
management of the equipment to ensure it remains demonstrably ‘safe for operation’; and (3) Each IPT shall
be required regularly to demonstrate to the Regulator that it is pro-actively managing the Airworthiness of its
platform by analysing maintenance data.
Recommendation 21.D.2: The Regulator shall provide independent analysis of maintenance data.