A quiet evolution has been occurring throughout the ADF over the last few years as the Directorate General Technical Airworthiness reforms the regulatory process to better align for the future.
Under the current leadership of Air Commodore Terry Saunder, Director General Technical Airworthiness, Australian Defence Force (DGTA-ADF), the reform process has been ongoing for the last five years and will continue to evolve over time.
Now in his fourth year as DGTA, AIRCDRE Saunder said that the current reforms can trace their roots back to a spate of accidents in the early 1990’s and also to a later policy to decentralise engineering from headquarters at RAAF Williams (Laverton) to the various Force Element Groups (FEG).
An organisational change followed in 2009 but even then it was realised that more fundamental or process change needed to occur.
“I had been here for three years as a Director before I moved into this role in, so we knew that we had to move away from how we viewed the world and that our product probably needed closer scrutiny,” AIRCDRE Saunder told ADM in March.
While he was a Director, DGTA-ADF representatives visited international regulatory bodies, including ICAO in Montreal and the newly-formed UK MAA to collect information.
“We regulate about 200 organisations in both Defence and industry, roughly split about 50:50 between engineering and maintenance,” he said. “My rules and regulations influence an estimated 8500 people, so I have to be very careful of how I communicate and educate.”
Harbinger of change
AIRCDRE Saunder said his team began formulating the ideas for reform in 2011, the first year in his current role, but quickly realised the organisation was very comfortable with the status quo.
“So we had to go through the usual change management process and I was very selective with succession planning,” he recalled. “It’s a challenge to take us away from the regulatory compliance model to a regulatory plus a safety performance view.”
Internal surveys were undertaken and KPMG were engaged to speak with fleet commanders, senior engineers and the DMO. On-line surveys were also sent to people at the chief engineer level to gather feedback.
“We don’t have an external focus, we’re very much an organisation that is looking at ourselves and we need to change that,” AIRCDRE Saunders said of the results. “We need to have a better external focus than we do and better understanding of what their context is so when we regulate we do it with a better understanding of those we regulate. We needed to mature and start to drive towards regulatory excellence.”
Implementing reform
About 400 ideas were gathered and distilled down to around two dozen for implementation, but not all have proven successful.
“Some of the projects were an absolute flop. For example, we tried to do some reform across the regulatory environment – between land, maritime and aviation,” AIRCDRE Saunders recalled. “I think we now have a better understanding of each other’s requirements but I wouldn’t say we’ve got as far as our initial vision.”
One area in which reform has proved successful however is the migration of 5000 hard copies of the Technical Airworthiness Management manual (TAM) to an on-line E-TAM, which is both easier to control and cheaper to update and DGTA is now looking at moving to an interactive electronic regulatory manual.
AIRCDRE Saunder also says that the changes to be done which will improve safety may be culturally challenging to the wider organisation but are not fundamentally different to what is done today.
“I have to be very careful how I implement change, because the people in the field have had a perception of the existing rules for a long time, so now I’m trying to reset that perception through education and the rewriting of guidance,” he detailed.
“We’re a hierarchical structure; we’re military, we go to war, we’re told what to do and there’s an underlying compliance culture – there always will be in the military, because that’s the way we operate in war. But I’ve got to give them enough flexibility to make informed decisions.
“I think we should always be an organisation that learns and listens. We will finish reform this year, with a view to being a continuous improvement organisation.”
Continuing improvement
The goal for 2014 is to complete the rewriting of guidance, to narrow the understanding of what DGTA is trying to achieve.
“We’re finding some of the rules also need to change as well but that will come later, everyone who was compliant yesterday will still be compliant, but they will have more clarity and flexibility,” AIRCDRE Saunders said.
Safety Management Systems are being developed over the next three or four years to endow good practice in the maintenance space and provide a better view of safety performance and understanding and risk management etc.
“We are also aware of what’s going on internationally; the European Defence Agency has a program to harmonise military regulations and they have European Military Aviation Requirements, which each country has to turn into some form of regulations,” the AIRCDRE said. “We are looking at restructuring our regulations, but not fundamentally changing their intent.”
A Future Aviation Regulation Environment project has been stood up and during the course of this year will define options ahead of a decision by the end of the year. However, implementation will be a multi-year program and AIRCDRE Saunder predicts that current regulations will exist for another decade.
Options for change also include an overhaul of the existing bespoke regulatory system or a replication of the EASA Part 145 maintenance organisation regulations within the military framework.
“We’ve just finished a study of our current regulations and their intent to Part 145, both CASA and EASA, and we’re about 75 percent common in intent,” the AIRCDRE noted. “We have some things like contingency maintenance - battle damage repair for example - that you wouldn’t expect to see in the civilian space, so we’re going back to do some analysis on the remaining 25 percent and although we would need to change a lot of terminology, fundamentally the intent is not different.
“I don’t want to pre-empt anything, but there could be similar examples in the Asian region where, if we can interpret another country’s system and they can interpret ours, it might be easier for us for example to put our KC-30 tanker into a Part 145 facility that can do (civilian) A330 work and we can be quite accepting of the fact that it’s being done in a civil facility versus a military one.”
AIRCDRE Saunder noted the ADF already operates the 737-based BBJ and Wedgetail and will introduce the P-8A Poseidon over the next few years. In addition to the KC-30, the Beechcraft King Air is fundamentally a civil platform and the Eurocopter EC135 being acquired under Air 9000 Phase 7 will also not differ markedly from its civil baseline.
“Let’s not just think military, but think aviation, we’ve got a whole lot of aircraft that come out of the civilian space,” he concluded. “If we can do it far more effectively then we don’t put more overheads on industry, which we and the public end up paying for.”
