In 2006 a fire aboard RAF Nimrod maritime patrol aircraft XV230 caused it to crash in Kandahar, Afghanistan, killing all 14 crew members on board. It was the biggest single of British military loss of life since the Falklands war and catalysed a grass-roots change to the way the UK Ministry of Defence (MOD) does safety, triggering it to form the Defence Safety Authority (DSA) in 2015.
Hosted by SMi Group with DSA, the first Defence Safety Conference took place in London in October, aiming to identify what works and what the defence community could do better against a background of increasing complexity. Attendees included highly decorated military personnel from 11 countries and senior defence company executives.
Reducing unnecessary risk through safe operating environments
Military service is by definition high-risk, but many deaths and injuries could be avoided through a whole-force approach and an open relationship with industry to promote better understanding, transparency and trust. The DSA’s ultimate aim is to make capabilities safe to operate, enabling personnel to operate safely in a safe environment.
The MOD established the DSA as a supra-service organisation to raise the profile of safety across the defence spectrum. Its director general, Lieutenant General Richard Felton, opened the Defence Safety Conference. He said the key aims were to see how safety can be best integrated into procedures, how to share best practice with industry and reduce the burden of certification.
“There is a myth that being safe means being risk-averse,” Felton said. “The review by Charles Haddon-Cave into the Nimrod XV230 incident criticised the existing process. He described what he found as too complex, too bureaucratic, lacking accountability, and lacking priority in terms of safety. Safety was being sacrificed to cut costs, with budgets driving behaviours. He identified the potential pitfalls of cumulative structural and organisation change on safety.”
Ensuring accountability and independent guidance
Haddon-Cave concluded a defence focus on safety would never be enough unless it came with a way of doing it properly with clear lines of responsibility, authority and accountability, which is where the DSA comes in. Its empowerment comes by personal charter, signed by the Secretary of State for Defence, which empowers Felton as safety authority, regulator and accident investigator.
“What the DSA stands for extends over all MOD civil servants, armed forces and those operating under contract in the UK and overseas. Independence is enshrined by the charter, with the director general only accountable to the secretary of state and outside all other chains of command. It is the DSA’s responsibility to provide separation among those who own risk.”
As safety authority, the DSA writes safety policy, advises, guides and arbitrates. It has regulators in the maritime, land and aviation domains and for medical, ordnance, fire and nuclear safety.
“All these recognise the imperative in defence being different, in this need to maintain operational capability,” said Felton.
He explained that assurance is essential to the DSA’s mission. It provides health and safety and environmental policy, and risk-based assurance, regulation enforcement and investigation, with the purpose of enhancing defence capability and protecting reputation.
“Our aim at the DSA is to help risk owners reduce and ideally prevent injury and loss of life, to reduce the risk of losing or damaging equipment or capability, and reduce risk to the environment,” he said. “All risks should be tolerable and comply with UK law, reduced to a level that is known as low as reasonably practical. This is where further litigation is judged grossly disproportionate to cost, time and sacrifice.”
Assessing safety assurance across domains
One of DSA’s responsibilities is to produce the annual assurance report, which, after approval, is made available online to the public. Felton shared some key statistics from the latest April 2017 to March 2018 report.
“There were five safety-related deaths in the March to March reporting period,” he said. “This is in line with past years and represents just over three fatalities per one hundred thousand personnel. Incidentally, this is better than agriculture and the waste and recycling industries.
“12,077 injuries or ill health were reported last year. This was slightly up from the previous year’s report, but this could be down to better levels of reporting. Of those, training accounted for 52%, or nearly 3,300 injuries, and sport for 22%, or nearly 1,500 injuries. We’ve tried to put a cost to this. A conservative estimate is over 100,000 work days lost at a cost of some £120m, but I stress these figures are untested.”
The DSA assesses safety assurance to three levels – none, limited and substantial. Last year’s report baselined the measure across the MOD’s six regulated domains – aviation, land, maritime, ordnance, munitions and explosives, fire and nuclear.
This year, regulators assessed there to be limited assurance across defence as a whole, the same level as last year. Substantial progress was made in three of the six safety risks identified last year: the impact of organisational change, the provision of suitably qualified and experienced personnel (SQUEP) and safety assurance in the maritime and land domains. However, there was limited overall progress to the risk of mid-air collision, little or no progress in defence fuel and gas infrastructure, and fire safety had worsened.
Identifying risks that need action across defence
The report goes on to list those risks that are considered significant across all of defence due to the potential impact they could have if not acted upon.
“The impact of change on safety is at the top and is shown improved from last year,” said Felton. “New equipment brings with it new risks while equipment that’s kept or extended in service because of delays to the new stuff brings its own risks, especially in support.”
The next concerns risk caused by insufficient numbers of SQEP, which Felton said has featured in every defence safety report since 2005, and it is a lack of experience rather than qualifications which presents the biggest challenges to the armed services.
Another area of significant risk is mid-expedition refuelling and fire safety management, which in part led to this year’s increase in fire safety non-compliance, despite fewer fires and false alarms.
From the accumulated evidence, Felton said it had been possible to determine the most significant accident factors. There were: failure to follow procedures, a lack of appropriate supervision, the taking of inappropriate levels of risk, and the lack of, or inadequate, leadership.
“The latter point on leadership I regard as particularly important, as appropriate leadership is essential in developing and sustaining safety culture,” added Felton.
UK defence safety after Brexit
Like most other aspects of UK life, defence safety will be affected by Brexit.
“Whilst it is in the interest of both the UK and EU to strike a deal, in order to prepare for all scenarios, the DSA is also assessing the safety impact to defence in case of a no deal,” Felton said. “Based on the 76 technical notices issued so far by the government, the DSA’s current assessment is [that] for those areas that we regulate, defence safety regulators are confident there is no current need to materially change defence safety regulation. For safety matters regulated by statutory bodies, defence may need to amend this process to accommodate changes to safety-related UK law which arise through the EU reform act of 2018.”
Felton concluded by saying of the DSA: “It wasn’t formed through a white paper, it was a product of things being smashed together and made to work. I don’t think we’re perfect, but I think we have the ability to do most of the things that we need to do, especially in talking truth to power and trying to rectify some of their governance issues.