Redacted Redacted Redacted Redacted
Ref No: MAA/NPA/17/12
MAA NPA Form Revised Jan 17
NOTICE OF PROPOSED AMENDMENT: MAA/NPA/17/12 TITLE OF PROPOSAL: RA 1029 – Ship-Air Release – Stakeholder Roles and Responsibilities Stage of Development:
Consultation
Organizations and business sectors affected:
Aviation and Ship ODHs, DDHs, Ship PAs, TAAs, RN RTSA, and NCHQ CSAV
MAA-NPA Serial No:
MAA/NPA/17/12
RFC Serial No:
MAA_RFC_2017_003
MAA Originator:
DSA-MAA-CertMarAv2
Redacted
Date: 08 May 17
MAA Supervisor:
DSA-MAA-CertMarAv
Redacted
Date: 08 May 17
MAA Independent:
DSA-MAA-RegDAw
Redacted
Date: 08 May 17
MAA LegAd (if required):
DSA-MAA-Legad
Redacted
Date: 08 May 17
Cross-reference to other relevant amendment proposals or documents:
Not Applicable
MRPT Point of Contact details Rank and Name:
MAA Regulatory Publications Team Enquiries
Telephone Number mil/civ:
9679 - 84189 / 83914 / 82504
Email address:
[email protected]
Ver 6.0
030 679 - 84189 / 83914 / 82504
Page 1 of 4
Ref No: MAA/NPA/17/12
MAA NPA Form Revised Jan 17
[Desk Officers are to refer to Annex B for completion guidance.] Feedback Notes The Regulated Community are invited to offer feedback (where applicable) on the impact of the proposed change to publications covered under this NPA on the operation of your business, including: • • • • •
Timescale for implementation. Cost of implementation. Amendment to contract. Amendment to internal processes/orders. Resourcing the outcome of change.
The format for feedback is illustrated at Annex A and is available within a single Excel file on both internal and external MAA websites.
SUMMARY OF PROPOSED AMENDMENT Change: The amendment replaces the term "Platform Duty Holder (PDH)" with "Platform Authority (PA)", the term "Commanding Officer Duty Holder (CODH)" with "Ship Delivery Duty Holder (Ship DDH)", and incorporates a new stakeholder engagement meeting (the "Ship Air Release Steering Group"). The amendment also unifies the headings for Regulation, AMC, and GM to those used in the context section of the RA. Impact Assessment: The full impact can only be assessed after full implementation of the amended RA by the Regulated Community (RC); however it is anticipated that the RC will be required to amend their documentation to match the change in terminology, and to introduce the new "Ship Air Release Steering Group". Objective: To provide up-to-date terminology and a new level of stakeholder engagement. Courses of Action - Risk Evaluation. Do nothing: Not recommended. This would perpetuate out-of-date terminology and a reduced level of stakeholder engagement. Partial amendment: Not recommended. Partial amendment is not practical in this RA. Full amendment: Recommended. Incorporation of the full amendment would provide the clarity sought. Post Implementation Review: The MAA routinely review regulation; however, if the Regulated Community identify an issue with the RA they are invited to raise a Request For Change. Consultation period ends: 13 Jun 2017 The consultation period for this proposed amendment ends on the stated date. Please send your feedback, using the Response Form, via email to [email protected].
Ver 6.0
Page 2 of 4
Ref No: MAA/NPA/17/12
APPROVAL
Post
Approved by: (IAW MAA SOP 20 Matrix)
Name Redacted Redacted Rank
Ver 6.0
MAA NPA Form Revised Jan 17
DSA-MAA-Reg-DepHd Original, non-redacted, signed
Page 3 of 4
Annex B to MAA NPA Form Revised Jan 17
NOTICE OF PROPOSED AMENDMENT RESPONSE SHEET Respondent details: Organization
Comments: RA No./ Manual
Name
Chapter & Para No.
Impact assessment: RA No./ Chapter & Para No. Manual
Ver 6.0
Contact Number:
Comment
Email Address:
Proposed Amendment
Impact assessment
Page 4 of 4
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Regulatory Article 1029
RA 1029 - Ship-Air Release – Stakeholder Roles and Responsibilities Rationale
►RA1395 sets out the rationale for Ship-Air Release (SA Release) to be conducted on all Her Majesty’s (HM)/MOD Ship Class and Air System combinations. With stakeholder engagement required across a pan defence group it is essential that the specific roles and responsibilities of these stakeholders are clearly defined and understood. The SA Release process requires reciprocal understanding between each of these stakeholders and enduring engagement to ensure the continued safety of embarked aviation activity in HM/MOD Ships.◄
Contents
1029(1): Aviation and Ship ►Duty Holder (DH)◄: Roles and Responsibilities 1029(2): Ship Platform ►Authority (PA)◄: Roles and Responsibilities 1029(3): Air System Type Airworthiness Authority (TAA): Roles and Responsibilities 1029(4): Royal Navy Release to Service Authority (RN RTSA): Roles and Responsibilities 1029(5): SA Release - Stakeholder Engagement
Regulation 1029(1)
t f a r D r fo A P N
Aviation and Ship ►DH◄: Roles and Responsibilities 1029(1) For Ship/Air System combinations conducting embarked aviation in HM/MOD Ships, Aviation and Ship ►DHs◄ shall identify and establish ownership for the Risk to Life (RtL) associated with the integration of their respective platforms.
Acceptable Aviation and Ship ►DH◄: Roles and Responsibilities Means of 1. For Air System/Ship combinations conducting embarked aviation in HM/MOD Compliance Ships, Aviation and Ship ►DHs◄ should ensure that: a. The Safety Cases for the Air System and Ship demonstrate that the 1029(1) platforms can be safely operated together for the proposed embarked aviation activities. b. The RtL posed by the integration of the Air System with the Ship have been identified and their ownership determined and documented through engagement in accordance with ►(iaw)◄ the requirements of RA 1029(5). c. Any equipment hazards within Ship/Air System Equipment Safety Assessments which are mitigated by Defence Lines of Development (DLoD) for which the ►DHs◄ are responsible have been formally acknowledged by the ►DHs◄ to the Air System TAA/►PA◄ 1. d. ►Any change to the Ship/Air System intended usage which may require an amendment to the SA Release is to be communicated to the PA and RN RTSA at the earliest opportunity. 2. The development and use of SA Releases and/or clearances achieved through Operational or MPP-02 2 routes, should comply with the orders set out in BRd766 3.◄
As defined in ►DSA02-DMR – MOD Shipping Regulations for◄ Safety and Environmental Protection. ►MPP-02 Helicopter Operations from Ships Other Than Aircraft Carriers (HOSTAC). 3 BRd766 Embarked Aviation Orders.◄ 1 2
RA 1029 Draft for NPA
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Regulatory Article 1029
Guidance Material 1029(1)
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Aviation and Ship ►DH◄: Roles and Responsibilities 3. This Regulation is complementary to the Aviation ►DH◄ responsibilities in RA 1020 4 and RA 1205 5 and to the Ship ►DH◄ responsibilities set out in ►DSA02DMR Part C 6◄. 4. For embarked aviation activity in HM/MOD Ships, the Aviation ►DH◄ as a Ship-Facing ►DH◄ will assess the RtL posed to the Ship by his Air System and communicates these to the Ship DH Chain. Likewise, the Ship ►DH◄ will similarly communicate RtL posed to the Air System by the Ship, noting that the Ship’s Commanding Officer ►(CO) and Delivery DH (DDH) are◄ responsible for approving aviation activity from his Ship and, as an Aerodrome Operator ►iaw◄ RA 1026 7, is also Aviation DH-Facing to ensure that the Ship remains a safe environment in which the Air System can operate. 5. ►The DH may delegate responsibility for the SA Release process to the DDH 4 iaw the principles of RA 1020 and DSA02-DMR Part C.◄
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6. Thus, the Aviation and Ship ►DH◄ constructs are ‘DH-Facing’ to each other and are required to be cognisant of additional implications of conducting embarked aviation operations in the maritime environment to their respective Safety Management Systems. 7. ►BRd766 provides more detailed processes to be followed in the generation of SA Releases.◄
Regulation 1029(2)
Ship ►PA◄: Roles and Responsibilities 1029(2) The Ship ►PA◄ for aviation capable HM/MOD Ships shall be responsible for providing equipment which is safe to operate aviation through-life.
Acceptable Ship ►PA◄: Roles and Responsibilities Means of 8. Ship ►PAs◄ in their Aviation DH-Facing capacity 8 should: Compliance a. Hold a Letter of Air Safety Notification 9. 1029(2) b. Ensure that adequate resource, including sufficient Suitably Qualified and Experienced Personnel (SQEP) with appropriate Air Safety training, is apportioned to fulfil Air Safety related responsibilities.
c. Ensure that the aviation arrangements in all aviation capable Ships for which they are responsible conform to the following requirements through-life: (1)
They meet the design requirements specified in RA 1920 10.
(2) All equipment risk is reduced to As Low As Reasonably Practicable (ALARP) 11, culminating in the issue of Naval Authority Certification. (3) The design, construction, modification and maintenance of aviation arrangements in their Ships are conducted by organisations with appropriate expertise and experience. 9. To support the production of a SA Release Recommendation, Ship ►PAs◄ should provide evidence to demonstrate the suitability of their platform (Equipment DLoD) for embarking aviation► as defined in BRd766◄. 10. The Ship ►PA◄ should inform the Ship ►DH◄, and the RN RTSA, of modifications to the Ship or to its intended usage which may ►require the SA release to be amended.
RA 1020 ►Duty Holder and Duty Holder-Facing Organizations – Roles & Responsibilities◄. RA 1205 Air System Safety Cases. ►DSA02-DMR – MOD Shipping Regulations for Safety and Environmental Protection.◄ 7 RA 1026 Aerodrome Operator. 8 ►As defined in◄ RA 1020(4). 9 See RA 1003 Delegation of Airworthiness Authority and Notification of Air Safety Responsibility (DE&S). 10 RA 1920 Aviation Arrangements in Surface Ships, Equipment Standards. 11 As defined in ►PDSA02-DMR Part B◄. 4 5 6
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RA 1029 Draft for NPA
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Regulatory Article 1029
Acceptable 11. This regulation is complementary to the PA responsibilities set out in DSA02DMR Part C.◄ Means of Compliance 1029(2) Guidance Material 1029(2)
Ship ►PA◄: Roles and Responsibilities 12. The Ship ►PA◄ or delegated Air Safety representative(s) will have completed relevant and recognised Military Aviation Authority (MAA) Air Safety training and will demonstrate awareness of: a.
►MAA Series of Air Safety Regulations.◄
b. Aspects of Air System design which have an interface with the subject Ship. 13. The Ship ►PA◄ will jointly establish, with the TAA, formal Equipment DLoD Working Groups. Demarcation of Equipment DLoD responsibilities will be defined through provision of a joint Ship/Air System Interface Control Document (ICD).
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14. ►BRd766 provides more detailed processes to be followed in the generation of SA Releases.◄
Regulation 1029(3)
Air System TAA: Roles and Responsibilities 1029(3) For Air Systems required to conduct embarked aviation in the maritime environment in HM/MOD Ships, the TAA shall be responsible for providing equipment which is safe and suitable to conduct such aviation activities.
Acceptable Air System TAA: Roles and Responsibilities Means of 15. TAAs in their Ship DH-Facing capacity should: Compliance a. Ensure that adequate resource, including sufficient SQEP with appropriate Ship Safety training, is apportioned to fulfil roles which support the 1029(3) SA Release process.
b. Through their delegated Airworthiness and Air Safety chains, ensure that the Air Systems for which they are responsible conform to the following requirements through-life: (1) The Type Airworthiness of the Air System is considered safe and suitable for the proposed embarked aviation activities at sea.
(2) All Air System equipment risks associated with embarked aviation operations in HM/MOD Ships are reduced to ALARP.
16. To support the production of a SA Release Recommendation for their Air System, TAAs should provide evidence to demonstrate the suitability of their platform (Equipment DLoD) for embarked aviation at sea ►as defined in BRd766◄. 17. The TAA should inform the Aviation ►DH◄, and the RN RTSA, of modifications to the Air System or to its intended usage ►which may require the SA Release to be amended◄.
Guidance Material 1029(3)
Air System TAA: Roles and Responsibilities ►◄ 18. The TAA or delegated representative(s) will have completed relevant and recognised Defence Maritime Regulator (DMR) Ship Safety training and will demonstrate awareness of: a.
12
JSP430 12.
►JSP430 Part 3 Chapter 15 – Naval Authority Certification - Aviation.◄
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Regulatory Article 1029
Guidance Material 1029(3)
b.
UNCONTROLLED COPY WHEN PRINTED ►DSA02-DMR.◄
c. Aspects of Ships’ aviation arrangements design which have an interface with the subject Air System. 19. The TAA will jointly establish, with the Ship ►PA◄ formal Equipment DLoD Working Groups. Demarcation of Equipment DLoD responsibilities will be defined through provision of a joint Ship/Air System ICD. 20. ►BRd766 provides more detailed processes to be followed in the generation of SA Releases.◄
Regulation 1029(4)
(RN RTSA): Roles and Responsibilities 1029(4) The RN RTSA shall authorize, issue, and maintain the through-life integrity of the SA Release, on behalf of Senior Duty Holders (SDHs), for their respective Ship/Air System combinations.
t f a r D r fo A P N
Acceptable (RN RTSA): Roles and Responsibilities Means of 21. The RN RTSA should: Compliance a. Authorize and issue an initial SA Release and subsequent SA Release amendments. 1029(4) b. Provide assurance that all relevant Equipment DLoD related RtL apparent at the point of SA Release issue and subsequent amendments have been identified and addressed by the appropriate Aviation or Ship DH. c. Provide independent assurance that all DLoDs are at an appropriate level of maturity such that their effects upon the Equipment DLoD can be verified, both prior to initial issue of a SA Release and subsequently when there are modifications (see Paras ►10 & 17◄) to the Air System, Ship or their intended usage which affect the issued SA Release. d. Include within their Air Safety Management System, procedures that describe how changes to the SA Release are to be managed.
e. Be engaged with the Aviation and Ship ►DH’s◄ respective Air System and Ship Safety Case governance structure and provide assurance to the SDHs that the integrity of the SA Release is maintained.
Guidance Material 1029(4)
(RN RTSA): Roles and Responsibilities
22. Assistant Chief of Naval Staff (Policy) as the RN RTSA acts as the SA Release issuing authority on behalf of the Service SDHs. 23. Delegation of any aspect of responsibility to a Delegated Release to Service Authority (DRTSA) must be conducted ►iaw◄ RA 1021 13. 24. The RN RTSA will be responsible for the upkeep of the SA Release documentation which may be amended to reflect any changes to the design, the operation of, or the conditions in which the Ship/Air System combination are used. The responsibility for considering the possible effect of these changes on the Air System and Ship Safety Assessments, and subsequently Safety Cases, remains with the appropriate ►PA◄, TAA and Ship/Aviation ►DH◄. 25. Engagement with Safety Case governance structures will include assurance that an embarked aviation requirement is adequately articulated within the Aviation ►DH’s◄ Safety Statement and the Ship ►DH’s◄ Command Safety & Environmental Summary14 respectively.
13 14
RA 1021 Release to Service Authorities (RTSA) Roles and Responsibilities. As defined in ►DSA02-DMR – MOS Shipping Regulations for◄ Safety and Environmental Protection.
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RA 1029 Draft for NPA
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Regulatory Article 1029
Regulation 1029(5)
SA Release - Stakeholder Engagement 1029(5) Engagement between Aviation and Ship ►DHs◄, TAAs, ►PAs◄ and other required stakeholders shall be formally established, managed effectively and documented.
Acceptable Means of Compliance 1029(5)
SA Release - Stakeholder Engagement 26. ►DHs◄, TAAs and ►PAs◄ and other stakeholders who provide an input to the production of a SA Release should engage throughout the SA Release process to ensure that pan-DLoD factors which affect the safety of integrating the Ship/Air System combination are managed with responsibility for RtL established and owned by the appropriate DH. The following should be considered the minimum: a.
►Ship Air Release Steering Group (SA Release Steering Group).◄
b.
Ship-Air Working Group (Ship-Air WG).
c.
t f a r D r fo A P N Ship-Air Equipment Working Group (Ship-Air EWG).
27. This engagement should be formally directed by the respective Aviation and Ship ODHs and detailed within their respective Safety Management Systems. Routine management of this engagement should be conducted by DE&S. 28. Where responsibility for Ship-Air engagement is delegated to an appropriate empowered representative, the ►DH◄, TAA or ►PA◄ should ensure that the delegated representative is SQEP.
Guidance Material 1029(5)
SA Release - Stakeholder Engagement
29. Engagement between ►DHs◄, TAAs, ►PAs◄, the RN RTSA and other organizations involved in the SA Release process is essential in ensuring the safe integration of an Air System and Ship. This engagement will commence as early as practicable once the embarked aviation requirement has been established. With the exception of the following minimum requirements, the scale of stakeholder engagement may be tailored to meet the complexity of the subject Ship/Air System. ►SA Release Steering Group 15
30. The function of the SA Release Steering Group is to determine the priority for the SA Release effort, thereby directing the formation of the Ship-Air WG and Ship-Air EWG. Chaired by NCHQ CSAV - DACOS AV 16, represented by Air/Ship system DH, TAA, PA and the RN RTSA.◄ Ship-Air WG
► 17◄
31. The function of a Ship-Air WG is to provide a means by which both Aviation and Ship ►DH◄ chains have the opportunity to manage safety related Ship-Air issues. It is charged with compiling the evidence required to support the production of the DE&S SA Release Recommendation, ODH Safety Statement and ODH Command Safety & Environmental Summary of sufficient maturity to allow for the authorization of a SA Release by the RN RTSA. Its functional outputs may be achieved through standalone jointly chaired meetings, or through existing DH forums, attended by the required panDLoD stakeholders, which have a clear process to apportion ownership of RtL and manage associated mitigation across Aviation and Ship ►DH◄ boundaries. 32. Following the authorization of the SA Release, the WGs will evaluate the continued suitability of the integrated combinations across all DLoDs, and will convene until the Ship Class and Air System(s) in question are no longer required to operate together. When there are modifications to the Air System 18, Ship 19 or their intended
►As defined in BRd766 Annex EAO01(4)A. Navy Command Headquarters Carrier Strike & Aviation - Deputy Assistant Chief of Staff Aviation. 17 As defined in BRd766 Annex EAO01(4)B.◄ 18 Changes to the Air System or its characteristics such as All Up Mass (AUM), Electro-magnetic Compatibility (EMC) vulnerability or new role modifications. 19 Changes to the Ship or its characteristics such as a new Air Traffic Management (ATM) Radar, Flight Deck modifications or changes to the air wake caused by superstructure alteration. 15 16
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Regulatory Article 1029
Guidance Material 1029(5)
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integrated usage 20, the WGs will be used to determine the effect(s) on the Air System and/or Ship Safety Cases and subsequently the effect on the SA Release. Ship-Air EWG
► 21◄
33. This is a subordinate forum to the Ship-Air WG which considers the integration of a particular Ship Class and Air System across the Equipment DLoD only. As a minimum, attendance is required by representatives from the Ship ►PA◄ and Air System TAA who will co-chair the Equipment WG; if deemed necessary, the ►PA◄/TAA may request attendance from other stakeholders (eg: Equipment ►Authorities◄/Commodity Project Teams, Trials Organizations and ►DH◄ representatives). This Working Group is likely to deliver the majority of evidence necessary to generate the Equipment DLoD focussed SA Release Recommendation.
t f a r D r fo A P N 20
Changes to the operating envelope such as the introduction of Into Wind Landings, a Ship-borne Rolling Vertical Landing manoeuvre, etc. 21 ►As defined in BRd766 Annex EAO01(4)D.◄
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RA 1029 Draft for NPA
MAA NPA Form Revised Jan 17
NOTICE OF PROPOSED AMENDMENT: MAA/NPA/17/12 TITLE OF PROPOSAL: RA 1029 – Ship-Air Release – Stakeholder Roles and Responsibilities Stage of Development:
Consultation
Organizations and business sectors affected:
Aviation and Ship ODHs, DDHs, Ship PAs, TAAs, RN RTSA, and NCHQ CSAV
MAA-NPA Serial No:
MAA/NPA/17/12
RFC Serial No:
MAA_RFC_2017_003
MAA Originator:
DSA-MAA-CertMarAv2
Redacted
Date: 08 May 17
MAA Supervisor:
DSA-MAA-CertMarAv
Redacted
Date: 08 May 17
MAA Independent:
DSA-MAA-RegDAw
Redacted
Date: 08 May 17
MAA LegAd (if required):
DSA-MAA-Legad
Redacted
Date: 08 May 17
Cross-reference to other relevant amendment proposals or documents:
Not Applicable
MRPT Point of Contact details Rank and Name:
MAA Regulatory Publications Team Enquiries
Telephone Number mil/civ:
9679 - 84189 / 83914 / 82504
Email address:
[email protected]
Ver 6.0
030 679 - 84189 / 83914 / 82504
Page 1 of 4
Ref No: MAA/NPA/17/12
MAA NPA Form Revised Jan 17
[Desk Officers are to refer to Annex B for completion guidance.] Feedback Notes The Regulated Community are invited to offer feedback (where applicable) on the impact of the proposed change to publications covered under this NPA on the operation of your business, including: • • • • •
Timescale for implementation. Cost of implementation. Amendment to contract. Amendment to internal processes/orders. Resourcing the outcome of change.
The format for feedback is illustrated at Annex A and is available within a single Excel file on both internal and external MAA websites.
SUMMARY OF PROPOSED AMENDMENT Change: The amendment replaces the term "Platform Duty Holder (PDH)" with "Platform Authority (PA)", the term "Commanding Officer Duty Holder (CODH)" with "Ship Delivery Duty Holder (Ship DDH)", and incorporates a new stakeholder engagement meeting (the "Ship Air Release Steering Group"). The amendment also unifies the headings for Regulation, AMC, and GM to those used in the context section of the RA. Impact Assessment: The full impact can only be assessed after full implementation of the amended RA by the Regulated Community (RC); however it is anticipated that the RC will be required to amend their documentation to match the change in terminology, and to introduce the new "Ship Air Release Steering Group". Objective: To provide up-to-date terminology and a new level of stakeholder engagement. Courses of Action - Risk Evaluation. Do nothing: Not recommended. This would perpetuate out-of-date terminology and a reduced level of stakeholder engagement. Partial amendment: Not recommended. Partial amendment is not practical in this RA. Full amendment: Recommended. Incorporation of the full amendment would provide the clarity sought. Post Implementation Review: The MAA routinely review regulation; however, if the Regulated Community identify an issue with the RA they are invited to raise a Request For Change. Consultation period ends: 13 Jun 2017 The consultation period for this proposed amendment ends on the stated date. Please send your feedback, using the Response Form, via email to [email protected].
Ver 6.0
Page 2 of 4
Ref No: MAA/NPA/17/12
APPROVAL
Post
Approved by: (IAW MAA SOP 20 Matrix)
Name Redacted Redacted Rank
Ver 6.0
MAA NPA Form Revised Jan 17
DSA-MAA-Reg-DepHd Original, non-redacted, signed
Page 3 of 4
Annex B to MAA NPA Form Revised Jan 17
NOTICE OF PROPOSED AMENDMENT RESPONSE SHEET Respondent details: Organization
Comments: RA No./ Manual
Name
Chapter & Para No.
Impact assessment: RA No./ Chapter & Para No. Manual
Ver 6.0
Contact Number:
Comment
Email Address:
Proposed Amendment
Impact assessment
Page 4 of 4
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Regulatory Article 1029
RA 1029 - Ship-Air Release – Stakeholder Roles and Responsibilities Rationale
►RA1395 sets out the rationale for Ship-Air Release (SA Release) to be conducted on all Her Majesty’s (HM)/MOD Ship Class and Air System combinations. With stakeholder engagement required across a pan defence group it is essential that the specific roles and responsibilities of these stakeholders are clearly defined and understood. The SA Release process requires reciprocal understanding between each of these stakeholders and enduring engagement to ensure the continued safety of embarked aviation activity in HM/MOD Ships.◄
Contents
1029(1): Aviation and Ship ►Duty Holder (DH)◄: Roles and Responsibilities 1029(2): Ship Platform ►Authority (PA)◄: Roles and Responsibilities 1029(3): Air System Type Airworthiness Authority (TAA): Roles and Responsibilities 1029(4): Royal Navy Release to Service Authority (RN RTSA): Roles and Responsibilities 1029(5): SA Release - Stakeholder Engagement
Regulation 1029(1)
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Aviation and Ship ►DH◄: Roles and Responsibilities 1029(1) For Ship/Air System combinations conducting embarked aviation in HM/MOD Ships, Aviation and Ship ►DHs◄ shall identify and establish ownership for the Risk to Life (RtL) associated with the integration of their respective platforms.
Acceptable Aviation and Ship ►DH◄: Roles and Responsibilities Means of 1. For Air System/Ship combinations conducting embarked aviation in HM/MOD Compliance Ships, Aviation and Ship ►DHs◄ should ensure that: a. The Safety Cases for the Air System and Ship demonstrate that the 1029(1) platforms can be safely operated together for the proposed embarked aviation activities. b. The RtL posed by the integration of the Air System with the Ship have been identified and their ownership determined and documented through engagement in accordance with ►(iaw)◄ the requirements of RA 1029(5). c. Any equipment hazards within Ship/Air System Equipment Safety Assessments which are mitigated by Defence Lines of Development (DLoD) for which the ►DHs◄ are responsible have been formally acknowledged by the ►DHs◄ to the Air System TAA/►PA◄ 1. d. ►Any change to the Ship/Air System intended usage which may require an amendment to the SA Release is to be communicated to the PA and RN RTSA at the earliest opportunity. 2. The development and use of SA Releases and/or clearances achieved through Operational or MPP-02 2 routes, should comply with the orders set out in BRd766 3.◄
As defined in ►DSA02-DMR – MOD Shipping Regulations for◄ Safety and Environmental Protection. ►MPP-02 Helicopter Operations from Ships Other Than Aircraft Carriers (HOSTAC). 3 BRd766 Embarked Aviation Orders.◄ 1 2
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Regulatory Article 1029
Guidance Material 1029(1)
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Aviation and Ship ►DH◄: Roles and Responsibilities 3. This Regulation is complementary to the Aviation ►DH◄ responsibilities in RA 1020 4 and RA 1205 5 and to the Ship ►DH◄ responsibilities set out in ►DSA02DMR Part C 6◄. 4. For embarked aviation activity in HM/MOD Ships, the Aviation ►DH◄ as a Ship-Facing ►DH◄ will assess the RtL posed to the Ship by his Air System and communicates these to the Ship DH Chain. Likewise, the Ship ►DH◄ will similarly communicate RtL posed to the Air System by the Ship, noting that the Ship’s Commanding Officer ►(CO) and Delivery DH (DDH) are◄ responsible for approving aviation activity from his Ship and, as an Aerodrome Operator ►iaw◄ RA 1026 7, is also Aviation DH-Facing to ensure that the Ship remains a safe environment in which the Air System can operate. 5. ►The DH may delegate responsibility for the SA Release process to the DDH 4 iaw the principles of RA 1020 and DSA02-DMR Part C.◄
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6. Thus, the Aviation and Ship ►DH◄ constructs are ‘DH-Facing’ to each other and are required to be cognisant of additional implications of conducting embarked aviation operations in the maritime environment to their respective Safety Management Systems. 7. ►BRd766 provides more detailed processes to be followed in the generation of SA Releases.◄
Regulation 1029(2)
Ship ►PA◄: Roles and Responsibilities 1029(2) The Ship ►PA◄ for aviation capable HM/MOD Ships shall be responsible for providing equipment which is safe to operate aviation through-life.
Acceptable Ship ►PA◄: Roles and Responsibilities Means of 8. Ship ►PAs◄ in their Aviation DH-Facing capacity 8 should: Compliance a. Hold a Letter of Air Safety Notification 9. 1029(2) b. Ensure that adequate resource, including sufficient Suitably Qualified and Experienced Personnel (SQEP) with appropriate Air Safety training, is apportioned to fulfil Air Safety related responsibilities.
c. Ensure that the aviation arrangements in all aviation capable Ships for which they are responsible conform to the following requirements through-life: (1)
They meet the design requirements specified in RA 1920 10.
(2) All equipment risk is reduced to As Low As Reasonably Practicable (ALARP) 11, culminating in the issue of Naval Authority Certification. (3) The design, construction, modification and maintenance of aviation arrangements in their Ships are conducted by organisations with appropriate expertise and experience. 9. To support the production of a SA Release Recommendation, Ship ►PAs◄ should provide evidence to demonstrate the suitability of their platform (Equipment DLoD) for embarking aviation► as defined in BRd766◄. 10. The Ship ►PA◄ should inform the Ship ►DH◄, and the RN RTSA, of modifications to the Ship or to its intended usage which may ►require the SA release to be amended.
RA 1020 ►Duty Holder and Duty Holder-Facing Organizations – Roles & Responsibilities◄. RA 1205 Air System Safety Cases. ►DSA02-DMR – MOD Shipping Regulations for Safety and Environmental Protection.◄ 7 RA 1026 Aerodrome Operator. 8 ►As defined in◄ RA 1020(4). 9 See RA 1003 Delegation of Airworthiness Authority and Notification of Air Safety Responsibility (DE&S). 10 RA 1920 Aviation Arrangements in Surface Ships, Equipment Standards. 11 As defined in ►PDSA02-DMR Part B◄. 4 5 6
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Regulatory Article 1029
Acceptable 11. This regulation is complementary to the PA responsibilities set out in DSA02DMR Part C.◄ Means of Compliance 1029(2) Guidance Material 1029(2)
Ship ►PA◄: Roles and Responsibilities 12. The Ship ►PA◄ or delegated Air Safety representative(s) will have completed relevant and recognised Military Aviation Authority (MAA) Air Safety training and will demonstrate awareness of: a.
►MAA Series of Air Safety Regulations.◄
b. Aspects of Air System design which have an interface with the subject Ship. 13. The Ship ►PA◄ will jointly establish, with the TAA, formal Equipment DLoD Working Groups. Demarcation of Equipment DLoD responsibilities will be defined through provision of a joint Ship/Air System Interface Control Document (ICD).
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14. ►BRd766 provides more detailed processes to be followed in the generation of SA Releases.◄
Regulation 1029(3)
Air System TAA: Roles and Responsibilities 1029(3) For Air Systems required to conduct embarked aviation in the maritime environment in HM/MOD Ships, the TAA shall be responsible for providing equipment which is safe and suitable to conduct such aviation activities.
Acceptable Air System TAA: Roles and Responsibilities Means of 15. TAAs in their Ship DH-Facing capacity should: Compliance a. Ensure that adequate resource, including sufficient SQEP with appropriate Ship Safety training, is apportioned to fulfil roles which support the 1029(3) SA Release process.
b. Through their delegated Airworthiness and Air Safety chains, ensure that the Air Systems for which they are responsible conform to the following requirements through-life: (1) The Type Airworthiness of the Air System is considered safe and suitable for the proposed embarked aviation activities at sea.
(2) All Air System equipment risks associated with embarked aviation operations in HM/MOD Ships are reduced to ALARP.
16. To support the production of a SA Release Recommendation for their Air System, TAAs should provide evidence to demonstrate the suitability of their platform (Equipment DLoD) for embarked aviation at sea ►as defined in BRd766◄. 17. The TAA should inform the Aviation ►DH◄, and the RN RTSA, of modifications to the Air System or to its intended usage ►which may require the SA Release to be amended◄.
Guidance Material 1029(3)
Air System TAA: Roles and Responsibilities ►◄ 18. The TAA or delegated representative(s) will have completed relevant and recognised Defence Maritime Regulator (DMR) Ship Safety training and will demonstrate awareness of: a.
12
JSP430 12.
►JSP430 Part 3 Chapter 15 – Naval Authority Certification - Aviation.◄
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Guidance Material 1029(3)
b.
UNCONTROLLED COPY WHEN PRINTED ►DSA02-DMR.◄
c. Aspects of Ships’ aviation arrangements design which have an interface with the subject Air System. 19. The TAA will jointly establish, with the Ship ►PA◄ formal Equipment DLoD Working Groups. Demarcation of Equipment DLoD responsibilities will be defined through provision of a joint Ship/Air System ICD. 20. ►BRd766 provides more detailed processes to be followed in the generation of SA Releases.◄
Regulation 1029(4)
(RN RTSA): Roles and Responsibilities 1029(4) The RN RTSA shall authorize, issue, and maintain the through-life integrity of the SA Release, on behalf of Senior Duty Holders (SDHs), for their respective Ship/Air System combinations.
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Acceptable (RN RTSA): Roles and Responsibilities Means of 21. The RN RTSA should: Compliance a. Authorize and issue an initial SA Release and subsequent SA Release amendments. 1029(4) b. Provide assurance that all relevant Equipment DLoD related RtL apparent at the point of SA Release issue and subsequent amendments have been identified and addressed by the appropriate Aviation or Ship DH. c. Provide independent assurance that all DLoDs are at an appropriate level of maturity such that their effects upon the Equipment DLoD can be verified, both prior to initial issue of a SA Release and subsequently when there are modifications (see Paras ►10 & 17◄) to the Air System, Ship or their intended usage which affect the issued SA Release. d. Include within their Air Safety Management System, procedures that describe how changes to the SA Release are to be managed.
e. Be engaged with the Aviation and Ship ►DH’s◄ respective Air System and Ship Safety Case governance structure and provide assurance to the SDHs that the integrity of the SA Release is maintained.
Guidance Material 1029(4)
(RN RTSA): Roles and Responsibilities
22. Assistant Chief of Naval Staff (Policy) as the RN RTSA acts as the SA Release issuing authority on behalf of the Service SDHs. 23. Delegation of any aspect of responsibility to a Delegated Release to Service Authority (DRTSA) must be conducted ►iaw◄ RA 1021 13. 24. The RN RTSA will be responsible for the upkeep of the SA Release documentation which may be amended to reflect any changes to the design, the operation of, or the conditions in which the Ship/Air System combination are used. The responsibility for considering the possible effect of these changes on the Air System and Ship Safety Assessments, and subsequently Safety Cases, remains with the appropriate ►PA◄, TAA and Ship/Aviation ►DH◄. 25. Engagement with Safety Case governance structures will include assurance that an embarked aviation requirement is adequately articulated within the Aviation ►DH’s◄ Safety Statement and the Ship ►DH’s◄ Command Safety & Environmental Summary14 respectively.
13 14
RA 1021 Release to Service Authorities (RTSA) Roles and Responsibilities. As defined in ►DSA02-DMR – MOS Shipping Regulations for◄ Safety and Environmental Protection.
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Regulation 1029(5)
SA Release - Stakeholder Engagement 1029(5) Engagement between Aviation and Ship ►DHs◄, TAAs, ►PAs◄ and other required stakeholders shall be formally established, managed effectively and documented.
Acceptable Means of Compliance 1029(5)
SA Release - Stakeholder Engagement 26. ►DHs◄, TAAs and ►PAs◄ and other stakeholders who provide an input to the production of a SA Release should engage throughout the SA Release process to ensure that pan-DLoD factors which affect the safety of integrating the Ship/Air System combination are managed with responsibility for RtL established and owned by the appropriate DH. The following should be considered the minimum: a.
►Ship Air Release Steering Group (SA Release Steering Group).◄
b.
Ship-Air Working Group (Ship-Air WG).
c.
t f a r D r fo A P N Ship-Air Equipment Working Group (Ship-Air EWG).
27. This engagement should be formally directed by the respective Aviation and Ship ODHs and detailed within their respective Safety Management Systems. Routine management of this engagement should be conducted by DE&S. 28. Where responsibility for Ship-Air engagement is delegated to an appropriate empowered representative, the ►DH◄, TAA or ►PA◄ should ensure that the delegated representative is SQEP.
Guidance Material 1029(5)
SA Release - Stakeholder Engagement
29. Engagement between ►DHs◄, TAAs, ►PAs◄, the RN RTSA and other organizations involved in the SA Release process is essential in ensuring the safe integration of an Air System and Ship. This engagement will commence as early as practicable once the embarked aviation requirement has been established. With the exception of the following minimum requirements, the scale of stakeholder engagement may be tailored to meet the complexity of the subject Ship/Air System. ►SA Release Steering Group 15
30. The function of the SA Release Steering Group is to determine the priority for the SA Release effort, thereby directing the formation of the Ship-Air WG and Ship-Air EWG. Chaired by NCHQ CSAV - DACOS AV 16, represented by Air/Ship system DH, TAA, PA and the RN RTSA.◄ Ship-Air WG
► 17◄
31. The function of a Ship-Air WG is to provide a means by which both Aviation and Ship ►DH◄ chains have the opportunity to manage safety related Ship-Air issues. It is charged with compiling the evidence required to support the production of the DE&S SA Release Recommendation, ODH Safety Statement and ODH Command Safety & Environmental Summary of sufficient maturity to allow for the authorization of a SA Release by the RN RTSA. Its functional outputs may be achieved through standalone jointly chaired meetings, or through existing DH forums, attended by the required panDLoD stakeholders, which have a clear process to apportion ownership of RtL and manage associated mitigation across Aviation and Ship ►DH◄ boundaries. 32. Following the authorization of the SA Release, the WGs will evaluate the continued suitability of the integrated combinations across all DLoDs, and will convene until the Ship Class and Air System(s) in question are no longer required to operate together. When there are modifications to the Air System 18, Ship 19 or their intended
►As defined in BRd766 Annex EAO01(4)A. Navy Command Headquarters Carrier Strike & Aviation - Deputy Assistant Chief of Staff Aviation. 17 As defined in BRd766 Annex EAO01(4)B.◄ 18 Changes to the Air System or its characteristics such as All Up Mass (AUM), Electro-magnetic Compatibility (EMC) vulnerability or new role modifications. 19 Changes to the Ship or its characteristics such as a new Air Traffic Management (ATM) Radar, Flight Deck modifications or changes to the air wake caused by superstructure alteration. 15 16
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integrated usage 20, the WGs will be used to determine the effect(s) on the Air System and/or Ship Safety Cases and subsequently the effect on the SA Release. Ship-Air EWG
► 21◄
33. This is a subordinate forum to the Ship-Air WG which considers the integration of a particular Ship Class and Air System across the Equipment DLoD only. As a minimum, attendance is required by representatives from the Ship ►PA◄ and Air System TAA who will co-chair the Equipment WG; if deemed necessary, the ►PA◄/TAA may request attendance from other stakeholders (eg: Equipment ►Authorities◄/Commodity Project Teams, Trials Organizations and ►DH◄ representatives). This Working Group is likely to deliver the majority of evidence necessary to generate the Equipment DLoD focussed SA Release Recommendation.
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Changes to the operating envelope such as the introduction of Into Wind Landings, a Ship-borne Rolling Vertical Landing manoeuvre, etc. 21 ►As defined in BRd766 Annex EAO01(4)D.◄
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