MAINTENANCE REGULATIONS

Billed as the most significant change in military maintenance regulations in decades, the UK Ministry of Defence's Maintenance Approved Organisation Scheme (MAOS) seeks essentially to better align military support structures with those in the civil world.

The MoD has now rolled out the MAOS organisation approval scheme for maintenance and continuing airworthiness management activities with Military Parts 145, M, 147 and 66 - essentially mirroring the regulatory model of the civil regulatory framework established by the European Aviation Safety Agency.

Previously, all platform-support arrangements had been determined differently by the integrated project team leaders, typically awarding contracts on an ad-hoc basis and simply requiring IS0 9000 minimal requirements.

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 BAE Systems is one UK company that has already secured approval under the new rules
The quiet revolution that stands to affect the huge network of civilian organisations that provide availability and maintenance under contract finds its origins in the UK Defence Industrial Strategy prescription of an increasing level of maintenance outsourcing.

The response to establish a regulatory structure to enable greater involvement in managing the MoD's aircraft fleets was borne from a collaborative effort by the MoD and the Society of British Aerospace Companies dating back to 2002.

"It was clear then that some of the things we were asking industry to do was not possible with the regulatory tools we had to hand," says Capt Steve Greenwood of the Royal Navy, who heads the MoD's continued Airworthiness Regulator.

He has led much of the work in the past two years to get civil service providers to adopt the new UK defence standard.

An aeronautical engineer with 32 years of service and a qualified helicopter maintenance test pilot whose tours included a stint as chief aircraft engineer on the aircraft carrier HMS Ark Royal, he explains the genesis of MAOS.

The MoD and SBAC joined forces to ensure that the new regulatory suite would enable the transformation of support with greater industrial participation (the so-called "transformation staircase"), while preserving airworthiness and safety and allowing the MoD to continue as a self-regulator.

The rules had to span a spectrum of activity from conventional support to "contracting for capability", where, for instance, the MoD could let a contract for pilot training under which the contractor is responsible for everything apart from provision of the trainee pilot.

A suite of regulations were produced: Mil-Part-145, governing maintenance facilities and personnel Mil-Part-M, governing continued airworthiness management Mil-Part-147, governing training facilities and Mil-Part-66, governing the licensing of engineering certificating staff.

"In the same way as a number of other European military operators have done, we decided to adapt the existing suite of EASA regulations, with the commercial transport regulations as the core. The biggest problem we faced was applying MoD structure, especially making a distinction between owner and operator," says Greenwood.

With a blueprint based on the civil rules, 2006 saw the Mil-Part-145 regulations tested on a Panavia Tornado at RAF Marham, with Mil-Part-M being tested on the MoD side.

TRIAL SUCCESS

The success of those trials now means all military contractors require Mil-Part-145 approval, with all legacy contracts requiring approval within two years.

Essentially, any business acquainted with the strictures of EASA will find the move seamless, although the MoD gives greater emphasis to tool control than some elements of the civil sector. Any company requesting approval will need to provide an exposition, with compliance subsequently checked by a designated military compliance business.

The new regulations, Greenwood says, promise a less pedantic approach and more flexibility in how compliance is delivered. "The real secret of success is that we are now allowing industry to go away and do things without necessarily constraining them to use traditional military means of compliance".

One of the issues being addressed is the obligation on the approved organisations for facilities and infrastructure and some spares - even though they may be government furnished.

Those organisations that have already secured approval include BAE Systems, for Tornado depth maintenance Qinetiq's aircraft and target operations and Serco operations at RNAS Culdrose, in Cornwall and RNAS Yeovilton, in Somerset. Approval for 10 more maintenance organisations are expected by year-end

Greenwood leads a small team of, essentially, rule writers who have also been involved in audit. As the volume of approval work grew, he has entered into a partnership with aviation consultants Aviation Compliance, who carry out detailed audit, in support of the approvals, under his direction.

"All this is in line with the Defence Industrial Strategy, which was designed to pass more responsibility for airworthiness and maintenance to industry through integrated support contracts, with the end game to achieve mutual savings and economies of scale," says Greenwood.

These regulations will be applied to the support of the Eurofighter Typhoon, and also the Lockheed Martin Joint Strike Fighter once its support strategy is defined.

More work is required to determine the role and responsibilities of the MoD, but Greenwood see it evolving into a full airworthiness authority, mimicking the UK Civil Aviation Authority's role.

Greenwood hopes the CAA, which was invited to monitor and oversee regulatory activities covering civil aircraft on the military register, will eventually recognise and credit Mil-Part-145 along with other Mil parts.




Source: Flight International