Continuing Airworthiness

Airworthiness can be considered as the sum of: initial airworthiness and continuing airworthiness.  Roughly speaking, the first is the work that goes on before an authority issues a Type Certificate for an aircraft and the second is what happens afterwards when it goes into service.

So, let’s assume we have an aircraft designed, manufactured and certificated in accordance with a set of requirements ready to enter service.  It’s imperative that the aircraft is properly serviced and maintained, and problems are fixed as they are discovered.

To achieve this a continued airworthiness programme is needed to support an aircraft in service.

Included within this is the need for a maintenance programme.  The reason for maintenance is to control the rate of deterioration of an aircraft.  This is achieved by two types of maintenance.  The first is preventive maintenance that relies on inspection and repeated activities to identify and fix problems.  The second is remedial maintenance, which includes repairs, and fixing a problem after an abnormal event (heavy landing, bird or lightning strike etc.).  All the above can be done for each aircraft as it is needed and set against an agreed schedule.

However, the story doesn’t end at that point.  A continued airworthiness programme takes lessons learned from experience and applies them not just to one aircraft but to a whole fleet of the same design.  It’s a philosophy that requires problems to be identified and reacted to with the aim of preventing their recurrence.  That could be lessons learned from accidents, incidents, occurrences or analysis that wasn’t routine or planned.

Airworthiness is an integrated activity and so all the above impacts the approvals, processes and procedures that are applied.  To undertake the work of continuing airworthiness there are approved organisations and licenced personnel to certify that work has been properly completed.

These are few words to describe an extensive system that works on a global scale.  Airworthiness is a vital component of aviation that is ever vigilant so that we can fly safely.

Topsy-Turvy World

It’s strange the path Theresa May has taken.  During the UK referendum, that took place more than 500 days ago, she argued for staying in the European Union by making Security one of the reasons for doing so.  Now, as Prime Minister she has flipped and is unmoving in her pursuit of Brexit.  But on the platform at a major Security conference in Germany #MSC2018, she chooses agreements that are persuasive against Brexit.

It truly is a topsy-turvy world.  Whilst EU Member States move towards a permanent structured cooperation in #EUdefence, Theresa May opts to try to both Leave and Remain at the same time.

She keeps repeating arguments in favour of cherry picking that she must know go down like a lead balloon in Europe.  If Brexit happens, the future UK-EU relationship will be one where the UK is deemed a “third country”.  Now, it maybe that the EU will try to resolve security issues separately from Brexit.  Nevertheless, there’s no better deal than the one the UK has inside the EU today.

If ideology is getting in the way, there’s no doubt that its on both sides of the UK-EU negotiations.  Theresa May was not speaking to the raucous galleries of the House of Commons where there are too many zealots, here she was talking to Nation States.  It’s no good accusing the EU of lack of will for pragmatic cooperation when the red lines have been tabled by the UK.

When talking about a new Treaty, she says: “It must be respectful of the sovereignty of both the UK and the EU’s legal orders. So, for example, when participating in EU Agencies the UK will respect the remit of the European Court of Justice.”  This does seem to throw aside one red line and is pragmatic and the most positive line in the whole speech.

It truly is a topsy-turvy world.  One thing is clear, if Brexit happens, or not, a security partnership in Europe is not an option it’s an absolute necessity.  Grandstanding at the Munich Security Conference doesn’t much help.  Cooperation is essential to tackle such challenges as cyber-attacks.

I agree with Theresa May when she says: “Europe’s security is our security.”  The UK’s foreign policy will be defined by the common interests it has with the EU.  The best possible future would be one where the UK remains in the EU, working with our partners for the security of us all.

Johnson’s ramblings

Characteristically Foreign Secretary Boris Johnson’s speech starts off with a set of misrepresentations.  Faking the appearance of reaching out to: “those who still have anxieties” seems empathetic and understanding.  But, in my reading it’s just more show over substance.  Before the referendum vote of 23 June 2016, I campaigned on the High Street of Uxbridge and meet his constituents.  I can understand how many of them have become concerned about their MP’s hardened stance on Brexit.  After all it is a U-Turn.

He talks about three “fears” in the set-up of his speech.

Strategic: The cartoon characterisation of Britain’s place in Europe as a flight from the world for the protection of the European Union is wholly wrong.  The reality is that, along with France and Germany, we are a great leader within a union of common interests.  To leave is to give-up the advantages we have in both Europe and the world.

Spiritual: The Brexit vote has given a huge boost to nationalism, small-mindedness and xenophobia.  It doesn’t matter what the intention was in calling the vote the outcome is a ghastly polarisation that promotes the right-wing of politics as top dog.  This outcome is as anti-liberal, uncivilised and not the pragmatism that the world cherishes as so British.

Economic:  Objectivity is needed on this technical subject.  All the trustworthy indicators from responsible organisations point one-way.  This is not emotional “anxieties” or “fears” it’s just plain cold fact.  If a smaller percentage of commentators criticise the single market or the customs union then that’s a normal part of normal debate.

At least I can agree with Boris Johnson where he says it’s the government’s duty to advocate and explain.  However, the explanations in his speech offered nothing new and took for granted that the 16 million who voted to Remain would just be irritated further by his arguments.  In fact, it took Johnson few words to get to emotive language about the so called: “pro-EU elite in this country” and “the Euro-elite”.

Moving on, he has, to some extent recognised that those who voted Remain have entirely noble sentiments, a real sense of solidarity with our European neighbours and a desire for the UK to succeed.  To me that goes without saying.  True, there may be a minority of both Leave and Remain voters who wished to recklessly damage the UK but most acted in good faith.

Johnson persisted with his table of three “fears” or “anxieties”.  This pedestrian structure is laboured through most of the speech.  Security, Spirituality and Economics are taken in turn.

On the first, everything he says could be achieved as a strong Britain IN a strong EU.  His whole point is null and void because it makes no case for leaving the EU.  As expected Johnson steers clear of any reference to the downside of leaving our established partnership in Europe.

Yes, the British are European and global, but we have all that inside the EU.  Again, Johnson fails to highlight any advantages of Brexit.  He’s rather more comfortable talking about “cheapo flights to stag parties” as a journalist might be in newsprint.  But this is a Minister standing at a lectern.

One line concerns me greatly, namely: “If we get the right deal on aviation.”  Yet again doubt is thrown into the mix as to what deal might result from UK-EU negotiations.  “If” is a big word.

Myths continue to be perpetuated as he rambled on.  Up rears the nonsense that somehow Brexit is a matter of regaining something we have lost.  Then to compound the mythmaking Johnson ran down the rabbit hole of European integration.  The more he continued the further he seemed to be stoking up fears and anxieties rather than allaying them for people.  The more he continued the less sense his vague view of Britain’s future seemed to make.  The more he continued the more he made the case to exist Brexit with haste.

Airworthiness Certification

Airworthiness is about past, present and future.  It’s about aircraft, procedures and people.  Its about design, manufacturing, maintenance, repair and overhaul.  That said, when it comes to what people do and the life-cycle of an aircraft there are two distinct phases.  Put simply, one is all the work that goes on before an aircraft enters service and the other is that work done for an aircraft in service.  The end of the life cycle of an aircraft doesn’t get nearly as much attention.  It’s is a subject that is of growing interest, as the afterlife is all about recycling and reuse of aircraft components.

Back to the two phases and they can be called; Initial Airworthiness and Continuing Airworthiness.  Each has its own ways of doing business, technical language and even its own specialised professions.  Here, I’ll rough out a description of Initial Airworthiness based upon how they are seen from the regulatory point of view.

Initial Airworthiness goes from the first concept of a new product, through design and manufacture all the way up to the day that a Type Certificate (TC) is handed over.  That Type Certificate is a declaration that, an aircraft type meets a given Airworthiness Code.

If you ask why?  The place to go is an international document called ICAO Annex 8.  This contains, in broad terms, the technical standards concerning Airworthiness.  There are 192 ICAO Contacting States[1].   However, the number of ICAO States that design and manufacturing large aircraft for commercial use is small.

In principle, each ICAO States can establish its own Airworthiness Code.  In practice, most ICAO States select an established code and adopt it.  There are two major global players in this field; one is the Federal Aviation Administration (FAA) and the other is the European Aviation Safety Agency (EASA).  So, if you want to make a new large aircraft and operate in most places in the world, the first step is to secure a Type Certificate from either FAA or EASA or both.

Before I get into trouble, there are other Airworthiness codes and some historical ones too.  Canada has its own code.  Britain and France originally had their own codes.  It was the development of the Concorde supersonic aircraft in the early 1970s that led to the move towards a common European code.  It’s a challenging and difficult business maintaining and updating such codes especially if they must address the latest advanced technology.

From initial application, and the setting down of a certification basis, to the day of granting a Type Certificate, analysis and testing are demanding and rigorous.  Industry and Authorities specialist, in every aeronautical field are dedicated to ensuring that certification achieves its objectives.

Now, the Type Certificate is a measure of the fitness to fly of a type of aircraft.  Once that has been secured the next step is to get a Certificate of Airworthiness (CofA) to say that an individual aircraft complies with the agreed type design.  Then an aircraft is fit to fly.

[1] https://www.icao.int/MemberStates/Member%20States.English.pdf

 

Airworthiness – what’s that?

Now, I get asked the question: what is Airworthiness?  Now you might think the answer was easy.  Just for an analogy you might say; there’s Roadworthiness and Seaworthiness too.  Strangely enough the words; Spaceworthiness and Railworthiness are quite valid but not so often heard outside their fields.  Thus, Land, Sea, Air and Space are all covered.

With a different focus the word; Crashworthiness is often used.  Finally, new to the fold is the up and coming term of Cyberworthiness.

Unsurprisingly, these words are all associated with fitness, legality, safety, soundness and reliability.

In definitions my preference is for simplicity.  Several dictionaries go for the unpretentious definition of airworthiness as: “Fitness to fly”.  Now there are lot of implications associated with that level of brevity.  An aircraft one person considers fit to fly may be totally unfit in the eyes of another.  But, at least those three words get the general concept across because no one would want to knowingly fly in an unfit aircraft.  As one of the classics in aviation quotations sums up nicely: “Aviation in itself is not inherently dangerous. But to an even greater degree than the sea, it is terribly unforgiving of any carelessness, incapacity or neglect.[1]”

The next element is legality.  It’s not enough say; this aircraft is fit to fly so jump on-board and let’s go.  From the first days of flying it was quickly recognised that accidents and incidents were going to happen.  Some would be fatal.  Gradually a whole framework of legislation grew-up around flying with the aim of addressing the risks to aviators, their passengers and to the public.

In the early months of 1944, the US Government invited 55 Allied and Neutral States to attend a conference in Chicago.  This forward-looking proposal was to take on the issues and problems that were arising as aviation became more international.  52 States turned up and the outcome was the Convention on International Civil Aviation.  This Chicago Convention was signed in December 1944

Airworthiness was not the first concern of this gathering but the process that followed soon realised that international standards and practices were going to be needed.  So, the International Civil Aviation Organisation (ICAO) was born.  Under Article 37[2] of the Chicago Convention, ICAO is obliged to adopt international standards addressing the airworthiness of aircraft and the licencing of personnel.

Airworthiness became a measure of an aircraft’s suitability for safe flight.  ICAO defines the word “Airworthy” as the status of an aircraft, engine, propeller or part when it conforms to its approved design and is in a condition for safe operation.

For practical purposes, Airworthiness can be considered as the sum of:

  1. An aircraft designed, manufactured and certificated in accordance with requirements;
  2. A continued airworthiness programme to support the aircraft in service;
  3. A maintenance programme to ensure the aircraft is properly serviced and maintained and
  4. Availability of licenced personnel to certify that tasks associated with the above have been properly completed.

Here you can see that Airworthiness has become an aircraft plus a process to assure suitability for safe flight.  Today that’s what it is as interpreted and implemented across the globe.

[1] Captain A. G. Lamplugh, British Aviation Insurance Group, London. c. early 1930’s.

[2] https://www.icao.int/publications/Documents/7300_orig.pdf

 

A European approch to Airworthiness

The JAA’s work began in 1970 (when it was known as the Joint Airworthiness Authorities).  Originally its tasks were to produce common certification codes for large aeroplanes and for engines.  This was to meet the needs of European Industry and particularly for products manufactured by international consortia.  From 1987, its work was extended to operations, maintenance, licensing and certification/design standards for all classes of aircraft.

The Joint Aviation Authorities (JAA) was an associated body of the European Civil Aviation Conference (ECAC) representing the civil aviation regulatory authorities of many European States who had agreed to co-operate in developing and implementing common safety regulatory standards and procedures.  This co-operation provided high and consistent standards of safety and a “level playing field” for competition in Europe.  Much emphasis was placed on harmonising regulations.

The JAA Membership was based on signing the “JAA Arrangements” document originally signed by Member States in Cyprus in 1990.  The objective was to ensure, through co-operation amongst Member States, that JAA members achieve a high, consistent level of aviation safety.  In addition to achieving a cost-effective safety system to contribute to an efficient civil aviation industry.

This situation changed in 2002 as a new regulatory framework was created for European aviation.  With the adoption of the Regulation (EC) No 1592/2002 by the European Parliament and the Council of the European Union (EU) the setup of the European Aviation Safety Agency (EASA) was given the green light.

The European Aviation Safety Agency (EASA), formally started its work on 28 September 2003, taking over the responsibility for regulating airworthiness and maintenance issues for the EU Member States.  EASA moved into its first headquarters in Cologne, Germany in November 2004.  At its early stages a roadmap was established to manage the transition from the JAA to the EASA system.

In November 2005, the EU Commission began the legislative process to amend EASA Regulation (EC) 1592/2002 to extend the competences of EASA into the fields of operations and licensing.

The ECAC Directors General decided to disband the JAA system from 30 June 2009 but to keep a JAA Training Organisation.  Thus, Europe established one harmonised set of regulations for airworthiness.  Those regulations continue to develop to take on the new challenges aviation faces.

Once in a blue moon

IMG_1638Change doesn’t come for free.  It’s a common misconception that moving from one way of doing things to another can be done without a lot of effort.  Over simplification is used to persuade people to make a change because their reluctance may be difficult to overcome.  This is drama being played out big time in the Brexit debate.  Week after week, Brexit supporting politicians come up with bland statements to try to offer assurance and comfort to their supporters.  Last year, Liam Fox said; the Brexit deal will be the “easiest thing in human history”.  David Davis was criticised for his “simple and easy” Brexit claim.  Former Ministers have said trade talks should be “easy”.

Rather than relief this insipid populism sends a shiver down the spine of anyone who has had to do serious negotiations in the past.  Agreements and Treaties, by their nature, bond those who sign for a significant period.  If they didn’t do that, they would be worth the paper that they are written on.  All Treaties between States are, in fact, a pooling of sovereignty.  Such arrangements bind States to act and behave in a consistent manner, even in disputes.

As if it was a business, signing a mediocre contract can be an impediment and a danger to future success.  So, words matter, and they matter even more when they are put down in public to a loud fanfare.  That said, every practical business has contacts.  Every successful State has Treaties.  It really is an embodiment of the John Donne’s words: No man is an island entire of itself.  We do not thrive when isolated from others, especially neighbours.

For all the reasons above the attack on British civil servants, over the weekend, was one of the most short-sighted folly’s that hard-line Brexit MPs have made so far, this year.  At a time when huge efforts are going to be needed to act with agility and creativity to draft a vast array of detailed texts, its not wise to hit the people you need.  It shows that those MPs who acted in this way have little comprehension for the impact of their actions.

In summary, this year has started with little achieved and a long journey ahead with not much time remaining.  All in all, a time when doubling or tripling of efforts are going to be needed rather than the insipid populism that is coming from senior politicians.  If Brexit happens under these circumstances, then some experts’ negative predictions wont just be predictions.

images old and new

IMG_1559The image of Britain standing in world wars against German domination has fed Euroscepticism in the UK.  Yes, German Ambassador, Dr Peter Ammon has a good point.

Being 57 years old, I can see the root cause of a degree of Euroscepticism in my generation and the one above me.  Please treat this observation as its intended.  Its not hostile.  There’s no way I’m saying that there is something inherently bad about everyone who watched TV or the movies in the 60s and 70s.

Many of the most wonderful films of my childhood are war stories.  Great drama and daring acts captured our imaginations in grainy black and white.  Often the theme has the undertones of David and Goliath, where huge odds are overcome to escape peril.  Danger on all sides as charismatic British actors portrayed heroic characters winning out.  I’ll just list a few classic movies that come to mind: The Flight of the Phoenix (1965), The Hill (1965), The Great Escape (1963), Ice Cold in Alex (1958) and A Matter of Life and Death (1946).  Love them all.

That was the setting.  The Sunday afternoon TV matinee movie was watched by many.  There wasn’t the proliferation of choice that the media present now.  No wonder many British people see the world through a prism of 20th century history.

Even wider than that, several of my Secondary School teachers revelled in telling stories of their war time experiences.  As children and young adults, we lapped up those stories even if they did generate occasional humour.  We would mock and mimic repeated tales in the manner of Monty Python.  It wasn’t being disrespectful.  It was a sense that the past and the modern world were inevitably in a tense battle for the future.  The future that we were to be a part of.

So, why am I not a Leaver?  I was too young to vote this the first referendum that took us into the Common Market.  That said, as a 15-year-old I was acutely aware of the debate.  In the West Country farming community, where I grew-up, it was a regular topic of conversation.  Local Conservatives were campaigning to stay in Europe.

From the day I left school, there’s been a European context to my further education and work.  I’ve been fortnuate to travel.  If I add it all up, over 40 years, and put the pros and cons on a set of scales they tip soundly in favour of being a part of the European Union.  Those scales tip that way whether I weigh-up facts or emotions.  Both my head and heart are convinced that Brexit is a dead end.  Let’s hope more and more people see it that way this year.

 

Blame game

IMG_1534Anytime something goes badly wrong its human to look around for something or someone to blame.  It often a destructive emotional human response to a grim situation.  However controlled, objective and rational you maybe its remarkably difficult to hold back and think through what’s going on without the temptation to lash out.  The closer a person is to the event in question the stronger the response.  After all its one thing to watch an accident unfold on a smartphone and its quite another to see it impacting people all around you.

When something bad happens, there are a need not only to deal with the essential first response, like putting the fire out or the search and rescue activities but the emotions and feelings too.  Brexit can be described as a car crash in slow motion.   It’s a crash that involves more than 65 million people in Europe.  Its consequences go much wider than that and truly send ripples around the globe.  Advocates of Brexit, naturally don’t see it like that often because of their intense emotional vow to see the crash course through to the bitter end.  Unfortunately, what we are seeing now in the daily news is a welling up of finger pointing blame peppering reports left and right.

I’m astonished to read that the UK Chancellor Philip Hammond is playing the blame game at such an early stage in the new year.  In reports, accusing the others of paranoia, at a time when negotiations between the EU and UK super sensitive, is to invite finger pointing.  Conservative Ministers seem wholly unable to offer reassuring messages and project a positive vision of the future.

There’s no doubt that there’s a growing ground swell of opinion in the UK that wishes there to be a second referendum on the question of EU membership.  That is the fairest and most reasonable way forward in what is a situation that is going badly wrong.  The people should be given a choice based not on theory, outlandish claims and brash polemic shouting but on the hard facts of a EU/UK deal.

The action that is democratic, respectful of the scale of the decision and soundly based on clear alternatives is a referendum on the results of negotiations.  This would be a first referendum that transform and turn around a destructive phase in our history.  If the EU/UK deal was accepted by the electorate then the Country could go forward with some unity.  If the EU/UK deal was rejected our leadership role in Europe will be re-established and the focus return to fixing the NHS, housing people and ensuring opportunity for all.

So, lets’ ditch the blame culture that has engulfed Westminster.  It’s time for great vision.  Its time for clear choices and time to trust the people with the facts.

Bespoke

IMG_1502I keep seeing the word “bespoke” in articles written about Brexit.  It’s the unspoken strategy of the UK Government for a tailored outcome to negotiations that is unique in its advantages and unlike any existing agreements the EU has with third Counties.  On the one point, there’s no doubt the UK’s position is unique.  To have been a big player in the EU for 40 years and then to leave it without a compass or a map is a special situation.

The impression given by the EU side in the negotiations is that the softest possible Brexit is sought but with no special advantages given that would incentivise other Countries taking a similar leap into the unknown.  Often the catch words; win-win are used to suggest that there’s an outcome that would mean the minimum pain around but that comes with a price.

These high-level aspirations are fine and good except that the detail is always in the fine print.  That said, in the world of regulation there’s an awful lot of fine print.  It’s the case that hardly any industry or service is solely domestic, in that all its rules are purely national.  Regionally and globally rules, regulations and standards are in place to ensure that markets work, and failure get fixed.    There’s no council of perfection, some are better than others in achieving their objectives and often changing agreements is a gruelling task.

Back to that word “bespoke”.  In regulatory rulemaking terms, it’s implied that three categories are likely to arise.  One: UK wholly adopts and applies a complete EU rule.  Two: UK creates and applies a regulatory equivalence to an EU rule.  Three: UK creates and applies a disharmonised rule.  For the first two categories, if the minimum of disruption is sought, changes and modifications would need to be synchronised between the UK and EU.

The last case, number three in my list, doesn’t have that much mileage given that many EU rules are designed to comply with higher level international rules.  I’m sure the UK would have the same overriding objective to remain compatible at an international level.

It’s certainly the result that a “bespoke” settlement will not be simpler than the existing situation as a Member State of the EU.  Not only that but the administration of all the above for all the industries and services would be a responsibility of the UK.  Repatriation of these responsibilities is going to need many administrators and technical staff and a sound structure for them to do their work.  Once in place, this is not static, and a continuous process of updating would be needed.

So, if I was to offer career advice for a young graduate in the post-Brexit UK you might guess what it would be.  Yes, there are going to be the need to train up many new people to take on this activity.