The Nimrod Review - Official Documents

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Objective
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Chapter 21 – New Military Airworthiness Regime
to operate. In the Civil Sector, operators also apply to EASA for a Certificate of Airworthiness for each specific
platform, renewed annually by an Annual Review Certificate (ARC) which confirms that the aircraft has been
maintained in accordance with the maintenance schedule by approved maintenance organisations and approved
tradesmen. Defence uses the F700 to provide an auditable record of maintenance that has been undertaken on
each of its aircraft and check whether the maintenance conforms with the maintenance schedule.
SCs in the MOD currently vary considerably in their format, content, length and value. In the absence of
clear guidance on what should constitute a SC, and what are acceptable means of compliance, over the
past eight years, IPTs have produced their own differing SC solutions. This has made it difficult for those with
Airworthiness responsibilities to make a relative assessment of one SC against another. Many SCs are, in any
event, too lengthy, complex and dense to provide a meaningful safety tool in the first place, let alone one
which is capable of ready use and assimilation by those most in need of it.
SCs in the MOD are currently deficient in that they have too narrow a focus. They normally do not include
an assessment of the risks of the use of equipment and other pertinent issues that have a direct bearing on
the Airworthiness of the platform such as spares, engineering standards and practices, or MOB manning
levels and experience. In contrast, the Australian Air Force undertakes a review of all of the Defence Lines of
Development (DLODs) relevant to the Airworthiness of a platform annually to ensure their equipment can
continue to be operated safely.
Hazard logs are formatted on the basis of probability. Therefore, those risks that fall into the catastrophic
impact category that are assessed to have a likelihood of occurrence of improbable are not deemed to be a
concern. The problem with this approach is that this assessment is based on the expected rate of arisings,
which is routinely determined on a small sample, particularly for a new aircraft. If a catastrophic event were
to happen, it would immediately elevate the assessment to probable and invite mitigation action; the Nimrod
accident is a potential example where the assessment of the likelihood of a fire and explosion was elevated
post the event happening, only then did it receive attention and mitigation action. The opportunity is therefore
being missed to mitigate the potentially catastrophic risks before the events happen; a fundamental flaw in
the philosophy for risk management that needs to be addressed.
There is a need to review and align the re-certification processes used by each of the three Services, and to
consider the benefits of adopting a military version of the civil Type Certificate, Certificate of Airworthiness
and Aircraft Release Certificate. Currently, each of the three Services has a different approach. This cannot be
sensible and the new MAA needs to address this.
The objectives of the Recommendations E below are: (1) First, to provide for each platform a concise and
useful SC that sets out the safety evidence for a platform, which can be readily assimilated and used as
evidence to support the Release to Service issued by the Regulating Authority. The SC needs to follow a
standard format to allow for independent assessment and comparison with other SCs. It also needs to be
in an easily accessible form so that it can be referred to by both the Regulator and the Duty Holder in the
operating authority throughout the platform’s life. (2) Second, to ensure that SCs are seen as a means to
an end, not an end in themselves, and the ‘box-ticking’ culture is replaced with pro-active management,
ownership and analysis of risk. (3) Third, to establish common criteria for managing Airworthiness risks across
DE&S and the AOAs for individual platforms, and for comparative assessment of all-platforms’ Airworthiness
risks. (4) Fourth, to align the certification process for military aircraft across the three Services, similar to the
civil certification process, in particular an AOA quality assurance system which looks far more closely at the
individual aircraft themselves, and audits which focus on actual compliance and maintenance standards. 42
42 Work is underway to realise this requirement under the ‘Can Do Safely’ campaign which is sponsored by Air Command, but which is currently
limited to the RAF’s AOA.
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