Category: Regulation

Safety Differences

Are the safety standards for all large aeroplanes the same? No, they are not. I’m never sure if the public naively expect this to be the case. I’m sure it’s not something that goes through the mind of every air traveller. Looking up at an aeroplane, flying overhead, this is not a thought that instantly comes to mind. Even watching them take-off and land at a busy airport.

A large aeroplane is a large aeroplane – surely. Well, not exactly. Several issue come into play when addressing the safety standards for large civil transport aeroplanes. For example, when did the type of aeroplane first go into service? What is it being used for? Where is it flying to? How many people are on-board?

One place to start with any discussion on this subject is with the basics. For a start an aeroplane is heavier than air and its power driven. Immediately, two important factors pop out of that definition. One: weight counts. Two: operating engine(s) are needed.

Almost lost in the mists of time are the reasons for dividing the world of transport aeroplanes into two categories. Simply called – large and small.

Underlying this basic categorisation is an historic assumption. This is an assumption upon which civil aviation safety regulation has been built. Namely, that efforts need to be made to ensure large aeroplanes are safer than small aeroplanes. One way of looking at this is to consider a spectrum of risk, and several parameters of concern.

Let’s start with the question above – what is it being used for? A transport aeroplane can be used to carry cargo or passengers, often both. The number of crew and passengers carried can range from 1 to 850[1]. In fact, for large aeroplanes, there’s no upper limit written into international standards. However, the term “very large aeroplane” is coined for the upper end of weight or passenger numbers carried. Sadly, the very largest of these very large aeroplanes (cargo), the Antonov An-225 Mriya, was destroyed by war.

Although, a matter of primary concern is the number of passengers carried, and therefore at risk in the event of an incident or accident, the main dividing line in the regulatory landscape between large and small aeroplanes is weight.

To some extent this has a foundation. It could be viewed that in the event of an incident or accident any resulting impact will be more severe the greater the weight of the aeroplane. This is where a parameter called the MTOW, or Maximum Take-off Weight, comes in. This number includes the total weight of an aeroplane, crew, fuel, passengers, and cargo.

Today, we divide the world of large and small aeroplanes based on MTOW. Yes, the maximum number of passengers that can be carried comes into the equation too. The question I have is, should that be the number one consideration?

[1] https://www.airwaysmag.com/legacy-posts/top-10-largest-passenger-aircraft

Public Broadcasting Value

It seems to be the season to have a downer on the BBC. As the gloomy light of winter gathers all around. The trees are shedding their leaves and that hunkering down mentality is invading my thoughts. Lawns no longer need mowing. Soden with moss and leaf fall.

I understand the dislike that partisan commercial broadcasters have for publicly funded broadcasters. The question of a “level playing field” and “bias” is always likely to come up.

Making a living from commercial advertising is highly competitive. Demands never stop. Seeking income from a marketplace that rises and falls with fashion and fad. That’s hard. Admittedly, there’s the compensating factor of wealthy benefactors or owners, prepared to make a loss, pumping funds into like minded companies. Shifting sands of political influence.

So, looking across the aisle at a major broadcaster that gets funds from the public, as a matter of law, must seem rather disconcerting. Certainly, it’s the sort of issue the wealthy benefactors or owners of media are going to kick at. Some to the extent of wanting to destroy chartered institutions with an ethos unlike their own.

What is a “level playing field” in the British media landscape? Can there ever be such a thing? That’s not an easy question to address. Shifting sands of public likes and dislikes shape the playing field (sorry about the metaphor overload). What might have been considered as independent, objective and neutral in the 1990s is way different from that now, 30-years on.

The British media landscape is not static, nor should it be so. In the period of three decades digital communication has advances at lightning speed. The sheer diversity of channels of communication has multiplied (even if they do repeat the same messages).

One sign of a healthy debate is the self-flagellation that the BBC often undergoes. As an institution, doesn’t it like to agonise about itself. With good reason considering some of the grave errors it’s made in the past. Supporting presenters whose behaviours have been found to be appallingly bad, and even criminal.

Let’s not tar everyone with the same brush. To be able to make mistakes and then correct them, with a good degree of learning in-between, is a strength. Some partisan commercial broadcasters seem unable to do this with any conviction. They just move on.

A publicly accountable broadcaster has no choice but to stand in the dock and take a reprimand, when appropriate. That’s no reason to shut it down. It’s a reason to make sure lessons are learned and not forgotten.

Doing a simple intuitive cost-benefit analysis. Taking the BBC as an example. What it offers, when it works well, far outweighs the costs. Listing three points, these have significant value: unifying impact of having a trusted national broadcaster, quality, broad base and originality of its output and editorial independence (not selling products or ideology).

Overseas critics may get upset, now and then, but that’s for them to get over. There’s no way such critics should shape the future of the broadcast media in Britain. That would be untenable.

Exploring Airworthiness Knowledge

How many good books are there on aircraft airworthiness? I don’t suppose a lot of people are going to ask that question. General introductions to airworthiness are not necessarily bedtime reading. This thought came to my mind, this week, because I had some time to kill in a library. A particularly technical library in London[1]. It’s at the Institute of Engineering and Technology (IET).

Sited in a grand building on the banks of the River Thames. Savoy Place, as the name suggests, is next door to the famous hotel of the same name. What marks it out is a large statue, not of some long-forgotten stage actor or army general, but that of Michael Faraday[2]. His contribution to the modern world is enduring and undeniable.

I’ve been a member of this august engineering institute since my student days in the early 1980s. Then it was known as the IEE. One “E” being for Electrical. Our lectures encouraged us students to join and once done so they have us for life. Members worldwide have access to their books, databases and standards.

I could draw a thread between Faraday’s work and 21st century aviation. It’s a mighty wide thread and one that’s growing all the time. There are so many aspects of electromagnetism embedded in aviation. For example, without electric motors and servos, we’d still be controlling aircraft with strings and wires. Fine, hydraulics play their part too.

Technology has moved on. It continues to move. Electrification is displacing hydromechanical systems. The age of electric propulsion is getting closer as developers experiment with a myriad of different configurations of motors for different new aircraft types. More and more electrical power is needed to make modern aircraft tick.

In the IET’s library there are a few books with the word “airworthiness” on the cover. It’s a distinct niche. More often technical references contain huge amounts of material that concern or impact airworthiness, but the word itself is reserved for the more discerning.

One I picked off the shelf was “Airworthiness: An Introduction to Aircraft Certification and Operations” by Filippo De Florio[3]”. For me it’s full of familiar material. I was surprised at the level of detail and range of coverage. In its latest version, it’s reasonably up-to-date too.

One book that was not on the IET’s shelf is “Initial Airworthiness: Determining the Acceptability of New Airborne Systems” by Professor Guy Gratton. I believe he’s updating this book now.

There was a copy of “Aircraft System Safety: Assessments for Initial Airworthiness Certification” by Duane Kritzinger. Again, for me it’s full of familiar material.

Another book that was not on the IET’s shelf is “Aircraft Continuing Airworthiness Management: A Practical Guide for Continuing Airworthiness Engineers” by Daniel Olufisan.

What I’m wondering now is how many other contemporary books are there on this subject. That is up-to-date references. Yes, I know I could do a quick search to turn up an easy answer but that tells me nothing of the quality of the publications. All four above are worth a read.

Help me out with some suggestions – please.

[1] https://www.theiet.org/membership/library-and-archives

[2] https://www.faraday.cam.ac.uk/about/michael-faraday/

[3] https://www.amazon.co.uk/Airworthiness-Introduction-Aircraft-Certification-Operations/dp/0081008880

The Future of Our Shared Values

That’s done. Reflecting on the last nine years. Time to look to the future. There’s no shortage of articles about the past and the present. Huge numbers of column inches crunch every detail of the current twists and turns of public life. Social media vibrates with repeated daily stories.

I watch a rebroadcast of HIGNFY[1] to quickly get the message that a headline is no basis for figuring out where we are going. Moments pass. Yes, there are reoccurring themes. What’s fascinating is that prominent personalities have their moments in the sun, and that they last a fraction of a second (metaphorically). The world moves on.

Yesterday’s scribblings concerned a degree of nostalgia. If only we could go back to some mythical age where current affairs seemed to make sense. Where people cooperated towards a common good. Where conflict was the exception not the rule.

Don’t look back. Don’t look back, too much. It’s a habit of the British to romanticise the past. Having such a colourful past to draw upon there’s always a story to tell. This inclination is at the root of our difficulties. It would be better to set a shared history as a foundation stone rather than always trying to build the same house.

Here in 2025, the world is being reshaped. There’s only so much that can be extrapolated from experience. Like a tsunami there’re changes happening that are unlike anything that has gone before. Early predictions of the benefits of digital technology imagined a borderless world. Information and learning spreading freely to enlighten and educate. So much for that.

It becomes clear that there are steps needed to protect and preserve our values. Enduring values underpinning our culture. They are not immutable. Forces acting at a global scale can, and do, shape how we think about our nation and what binds us together.

Whether we like it or not, many of the forces that shaped the colours on the world map are being played out in the digital sphere. Boundaries, barriers, conflicts, possessions, passions and powerplay are all there. Maybe they are not so visible to the man and woman on the Clapham omnibus, but they are there in abundance. As if we needed any indication, the experience of Jaguar Land Rover[2] and the cyber-attack they are dealing with, is there as a siren light.

I my mind these are not forces to confront in isolation. They do not respect lines on a map. Back to where I started. It’s by working with others, on an international level, that the harmful elements can be addressed.

The European Union (EU) envisions a Digital Single Market. That’s a project to be on-board. It’s essential to have standards that safeguard privacy and data security. Government Ministers who promote a hands-free laissez-faire approach are naive in the extreme. This is a practical field where Britian urgently needs to rebuild relations with its neighbours.

[1] https://www.bbc.co.uk/programmes/b006mkw3

[2] https://www.ft.com/content/6f2923b3-2a4b-4c9b-9cde-eb5f0d5b9ce3

Why Timely Aviation Safety Reporting Matters

Waiting for accident reports can be frustrating. I’ve found this to be the case in past experiences. When a major fatal aviation accident happens the demand for information is exceptionally high. That means that every credible source of information will be drawn upon.

I don’t think anyone expects professional aviation accident investigators to come up with instant answers. Extensive and meticulous work is required to arrive at detailed findings. When it’s possible accident investigators publish interim reports to ensure that relevant information becomes generally available.

Countering this reality is the need to ensure that the aviation system is not operating at elevated risk during the period that investigation is being conducted. Information needs to flow to those who are empowered to take corrective action.

Given the nature of international civil aviation, accidents can occur anywhere at any time. There’s no rule, statistical or otherwise, that can stop these extremely rare events occurring. Much as it’s fine to promote an ambition for zero accidents, it’s not going to happen.

The frustration I’ve pointed to is shared by industry and authorities. As time goes by the level of speculation and misinformation always increases where there is an absence of verifiable facts. There’s always a need for industry, authorities and investigators to cooperate. As often each one will have a part of the jigsaw that when put together describes what happened.

For all sorts of reasons, this necessary cooperation does not always exist or exist as a smooth pathway to resolving a situation and initiating corrective action. Where barriers exist and delays accumulate the collective aim of assuring aviation safety is harmed.

The International Air Transport Association (IATA), at their recent conference, highlighted this as being a significant issue[1]. There are international standards, but these standards are not always applied in the manner with which they were intended. It seems obvious to say. It’s essential to learn safety lessons and take corrective action as soon as it’s humanly possible.

Where sufficient resources are an issue then there must be cooperative arrangement to allow others to help. It’s by sharing expertise and equipment that the time between occurrence of an event and the implementation of risk reduction measures can be reduced.

Risk reduction measures do not always need to be the final measure. There are the conventional strategies for addressing aviation safety risk – reduce, eliminate or mitigate. Even if publication of a final accident report is a year or more away, there’s often much that can be done in the interim.

Bureaucratic protocols, political sensitivities and commercial interests are real. However, most governments have signed up to obligations within the ICAO convention and its standards. It’s recognised that timeliness is vital.

[1] https://www.iata.org/en/pressroom/2025-releases/2025-10-14-02/

Shifting Perspectives

Daily writing prompt
What’s a topic or issue about which you’ve changed your mind?
View all responses

If you write the perfect rule, you will get the desired outcome. Authoring a specification that is robust and watertight will assure success. Having the best possible plan will deliver the best possible results. All sounds reasonable – doesn’t it? It’s not surprising that someone like me, having been schooled in project management, and working in engineering, would have a rational and systematic approach to problem solving. A proven highly successful way of implementing complex technical projects and delivering successful outcomes.

As an analogy I’ll start with mathematics. Nature is a curious beast. What we lean about complex systems is that what happens is highly dependent upon a start point. The initial conditions. Graduate level mathematics about control systems with feedback show that their behaviour changes a lot with a change of initial conditions. So, it’s reasonable to extend that to a systematic approach to just about anything. It’s often true.

Fail to plan – plan to fail. That idiom is a simple few words to sum up this cause and effect. Used by famous names and often quoted. Management training books are littered with this notion.

20-years ago, my team introduced the first European Aviation Safety Plan[1]. This initiative was built around the idea that to achieve a common objective a plan is the best and quickest way to get there. A roadmap, a pathway, a strategy, call it what you will.

Start by identifying problems and then propose a fix for each one. Not all problems but the ones that fit that awkward Americanism – the low hanging fruit. Namely, the biggest problems (fruit) that can be solved with the least effort (easily picked).

Here’s where I’ve changed your mind. Maybe not changed in a dramatic sense but shifted perspective. It’s essential to have a plan, even if it’s just in my head, but it can be overstated as the most important part of a process of change.

The Plan, Do, Check, and Act (PDCA) cycle, starts with a plan. It must start that way. However, each of the four steps is equally important. Seems obvious to say. Even so, it’s often the case that a press release, or alike, will state – we have a plan, roadmap, pathway, strategy, as if that’s the job done.

Management teams will smile with a sense of achievement and show off their plans. A decade down the line that celebration might seem less momentous as the “do” part of the process turns out to be harder than anticipated.

This basic model for systematic change is a good one. Where I’ve changed my emphasis is in the distribution of effort. Don’t put all available energies into constructing the perfect plan. Yes, the initial conditions are important but they are not everything. The key part of the process is the cycle. Going around it with regularity is a way of delivering continuous improvement. Afterall, when it comes to a subject like aviation safety, that’s what’s needed.

[1] 2005 – DECISION OF THE MANAGEMENT BOARD ADOPTING THE 2006 WORK PROGRAMME OF THE EUROPEAN AVIATION SAFETY AGENCY

Unintended Consequences

There’s a list that must exist somewhere in the bowels of Government which describes the dumbest things that have ever been done. The law of unintended consequences. Where an aim may have been honest, but the reality was a deep dive in embarrassment and failure.

If this list doesn’t exist it dam well should. It’s a sort of lessons learned for civil servants, politicians and think tanks. Don’t propose anything X because the last time someone did that they crashed and burned. Or more subtly it was years later that people cursed the day that such a dumb idea was advanced.

I’m not going to argue against market forces. How could I. From an early age markets were part of my life. That’s local agricultural markets. My father bought and sold livestock. The bread and butter of livestock farming is to buy at one price, add value and then, hopefully, sell at a better price. Markets rise and fall in ways that are often mystical.

The UK imports approximately 46% of the food it consumes. Even that figure is 5 years old. I suspect that food imports have increased in the meantime. That’s in a country that is richly blessed with quality agricultural land. Fine, we (UK) are none too good at growing olives or avocados but the range of produce that it is possible to grow is huge.

Grassland is our greatest asset. Every time I flew back from an overseas trip, just looking down from the aeroplane remined me just how the UK is a carpet of green. Field systems that have ancient origins still dominate the landscape.

Livestock farming has changed radically since my father’s time. Fortunately, we have avoided, in most cases, the levels of intensification and factory methods that others have adopted. Hormone injected beef comes from cattle that live sad lives. People know this and have hands down rejected industrial farming to that level of intensity.

Domestic food production has changed because of Brexit and not for the better. One threat to domestic food production has been some of the ridiculous trade deals that have been struck by this Government and its predecessors. Making it harder for exporters and easier for importers.

Political policy towards the countryside has rightfully taken up the need to restore biodiversity and preserve some of our most precious landscapes. Trouble is that at the same time, little or no thought has been given to the need to support domestic food production. It’s like a policy desert. It’s one thing to talk about food security. It’s another to do anything about it.

With the Labour Government threatening to take large amounts of capital out of UK farming with their inheritance tax plans, they will be making family farming a thing of the past. It’s one of the dumbest things that have ever been done.

There’s general agreement that we shouldn’t encourage wealthy people to use land as a repository for their wealth. However, tax advisors have been telling them to do that for decades. Buy land and pay less tax. Reversing that long standing trend needs an intelligent policy not a crude sledgehammer to crack a nut. Even if it’s impossible to ween Labour politicians off their ideas on inheritance tax, there ought to be a way of doing it without penalising the innocent. Letting off those non-farming interests that politicians were aiming at originally. Dogma makes bad policy. It’s time to reemphasise the place family farming has in food production.

Regulatory Insights

I can’t remember if my teacher was talking about maths or physics. His scholarly advice has stuck with me. When things get complex, they can seem overwhelming. Problems seem insolvable. So, it’s good to take a deep breath, step back and see if it’s possible to reduce the problem to its most basic elements. Do what could be called helicopter behaviour. Try to look at the problem top-down, in its simplest form. Break it into parts to see if each part is more easily comprehended.

Today’s international aviation regulatory structure, for design and production, follows the arrow of time. From birth to death. Every commercial aircraft that there ever was started as a set of ideas, progressed to a prototype and, if successful, entered service to have a life in the air.

This elementary aircraft life cycle is embedded in standards as well as aviation rules. Documents like, ARP4754(), Aerospace Recommended Practice (ARP) Guidelines for Development of Civil Aircraft and Systems are constructed in this manner. There are as many graphs and curves that represent the aircraft life cycle as there are views on the subject, but they all have common themes.

That said, the end-of-life scenarios for aircraft of all kinds is often haphazard. Those like the Douglas DC-3 go on almost without end. Fascinatingly, this week, I read of an Airbus A321neo being scrapped after only 6-years of operations. Parts being more valuable than the aircraft.

Generally, flight-time lives in operational service are getting shorter. The pace of technology is such that advances offer commercial and environmental advantages that cannot be resisted. Operating conditions change, business models change and innovation speeds forward.

My earlier proposition was that our traditional aviation regulatory structure is out of date. Well, the detail is ever evolving – it’s true. Some of the fundamentals remain. The arrow of time, however fast the wheels spin, mixing my metaphors, remains an immobile reality.

In airworthiness terms an aircraft life cycle is divided into two halves. Initial airworthiness and continuing airworthiness. This provides for a gate keeper. A design does not advance into operational service, along the aircraft life cycle, until specified standards have been demonstrated as met. An authority has deemed that acceptable standards are met.

I’m arguing, this part of the aviation regulatory structure is far from out of date. However much there’s talk of so called “self-regulation” by industry it has not come into being for commercial aviation. I think there’s good reason for retaining the role that a capable independent authority plays in the system. A gate keeper is there to ensure that the public interest is served. That means safety, security and environmental considerations are given appropriate priority.

To fulfil these basic objectives there’s a need for oversight. That is the transparency needed to ensure confidence is maintained not just for a day but for the whole aircraft life cycle. And so, the case for both design and production approvals remain solid. The devil being in the detail.

Aviation Regulations Outdated?

Machines, like aircraft started life in craft workshops. Fabric and wood put together by skilful artisans. Experimentation being a key part of early aviation. It’s easy to see that development by touring a museum that I’d recommend a visit. At Patchway in Bristol there’s a corner of what was once a huge factory. In fact, somewhere where I worked in the early 1980s. Aerospace Bristol[1] is a story of heritage. A testament to the thousands who have worked there over decades.

Fabric and wood played part in the early days. The factory at Filton in Bristol started life making trams. An integral part of turn of the century city life. Carriage work brought together skilled workers in wood, metal and fabrics. It was soon recognised that these were just the skills needed for the new and emerging aircraft industry. The Bristol Aeroplane Company (BAC) was born.

It’s war that industrialised aviation. Demonstration of the value of air power led to ever more technical developments. Lots of the lessons of Henry Ford were applied to aircraft production. Factories grew in importance, employing a large workforce.

My time at the Filton site was in a building next to a hanger where the Bristol Bulldog[2] was originally produced. This was a single engine fighter, designed in the 1920s, in-service with the Royal Air Force (RAF).

Right from the start orderly processes and regulatory oversight formed part of aircraft design and production. The management of production quality started as a highly prescriptive process. As aviation grew into a global industry, the risks associated with poor design or faulty production became all too apparent.

In the civil industry, regulatory systems developed to address the control of design and production as two different worlds. Airworthiness, or fitness to fly, depended on having a good design that was produced in a consistent and reliable manner. So, now we have a regulatory framework with two pivotal concepts: DOA (Design Organisation Approval) and POA (Production Organisation Approval). It took about a century to get here. Now, these concepts are codified within EASA Part 21, FAA regulations, and other national aviation authorities’ frameworks.

Here’s my more controversial point. Is this internationally accepted regulatory model, that has evolved, conditioned by circumstances, the right one for the future? Are the airworthiness concepts of DOA and POA out of date?

This is a question that nobody wants to hear. Evolution has proved to be a successful strategy. At least, to date. What I’m wondering is, now the world of traditional factories and large administrative workforces is passing, how will regulation adjust to meet future needs?

Maybe I’ll explore that subject next.

[1] https://aerospacebristol.org/

[2] https://en.wikipedia.org/wiki/Bristol_Bulldog

Data Interpretation

More on that subject of number crunching. I’m not so much concerned about the numerous ways and means to produce reliable statistics as the ethical factors involved in their production.

Two things. One is the importance of saying truth to power and the other the importance of seeing things as they really are rather than how you or I would like them to be.

Starting with the first. If ever it was a hard day to say this but asserting truth is not one of several options, it’s the best option.

Whatever any short-term gains there are in distorting a description of a current situation, in the longer term the truth will out. Now, that may not have always been so. It’s often said that the victors write history. That famous view had some validity when literacy was not universal or when texts were chained in church libraries. Now, information speeds through the INTERNET (and whatever its successor will be). Controlling or supressing information has become like trying to build a castle out of sugar on a rainy day.

The second factor is more troublesome and, for that matter, more difficult. It could be the tug of war between subjectivity and objectivity. What we see is so much dependent upon the observer. What we hear is conditioned by what we’ve heard in the past.

I saw this often in the interpretation of a written narrative. Aviation accidents and incidents are reported. Databases full of multivarious reports of different origins siting there waiting to be read. This is a good thing.

It’s the choice of language that shapes our understanding of past events. That can be voluminous and contradictory. It can be minimalist and ambiguous. It can have peculiar expressions or fuzzy translations. Even if reporters are asked to codify their observations, with a tick box, there remains wide margins.

The writer of a story often knows what they want to say. It might be obvious to them what happened at the time of writing. Then it’s the reader who takes that up. A text could be read years later. Read by many others. Similar stories may exist, all written up differently. Hopefully, slight variations.

Seeing things as they really are, rather than how you would like them to be, without bias, requires more than a degree of care. A great deal of care.

It’s hard enough for an enlightened and skilled analysist to take a sentence and say “yes” I know exactly what happened. Not just what but all six of these – who, what, were, when, how and why. In future, the artificial intelligence tools that get used by authorities will have the same challenge.

For all our technological wonders, it’s the writers of reports that shapes our understanding. From a couple of sentences to a massive dissertation.

Try telling that to a maintenance engineer whose last job of the day, before going home, is to file an occurrence report after a terrible day at work. In a damp hanger with a job only half done. Tomorrow’s troubles looming.

POST: Rt Rev Nick Baines and his Thought for the Day on BBC Radio 4 is thinking the same this morning. Truth is truth. In his case it’s Christian truth that he has in mind. There lies another discussion.