Regulatory Reflections & Resisting the Seduction of the Risk Management Process

Regulatory Reflections & Resisting the Seduction of the Risk Management Process

In 2014 the UK Military Aviation Authority (MAA) Head of Regulation and Certification, Commodore Malcolm Toy presented reflections five years on from the Haddon-Cave Report, issued in October 2009, following the loss of Royal Air Force (RAF) Nimrod XV230, that resulted in a revolution in UK military aviation regulation and safety, including the formation of the MAA UK Military Aviation Authority (MAA).


The seven reflections have resonance for other regulators and organisations managing risk:

  1. You cannot be world class unless you know what the world is up to.
  2. Regulatory (safety) decisions must be evidence based and proportionate to the Risk to Life.
  3. Learn from near misses.
  4. Scarcity [of personnel, time and capacity] is a challenge and cannot be overcome without a plan.
  5. Do not be seduced by the process of managing risk.
  6. Regulators (Safety Organizations) do not play to win, they play not to lose.
  7. Put those organizations that have Risk to Life exposure at the centre of managing that risk.

The Process of Risk Management

Perhaps the most interesting are the comments on avoiding the allure of the process of managing risk.  Toy warns that simply ‘measuring’ risk is not actually the same as actively managing risk.  Managing risk needs actions to be planned and executed but some times it may seem easier to ‘tinker with’ risk than actually engineer solutions.

Commodore Toy’s full presentation can be found on the European Defence Agency website or here.

The MAA’s vision and mission for  2016 to 2021 has been published.

Haddon-Cave Nimrod Report Background

Haddon-Cave himself presented at a UK CAA event in 2010 and to the Piper 25 conference (marking the 25th anniversary of Piper Alpha offshore disaster in the North Sea, in which 167 workers died).  His paper was entitled “Leadership and Culture, Principles and Professionalism, Simplicity and Safety – Lessons from the Nimrod Review”:

Piper 25: Presentation Transcript

UPDATE 2 September 2016: 10 Year Anniversary: Loss of RAF Nimrod MR2 XV230

UPDATE 19 September 2016: It’s worth listening to Todd Conklin’s podcast interview with Prof Ed Schein.

UPDATE 22 September 2016: NTSB Board Member Robert L. Sumwalt presented Lessons from the Ashes:
The Critical Role of Safety Leadership to an audience in Houston, TX.  Its worth noting the emphasis made of safety as a ‘value’ and of alignment across an organisation.

UPDATE 1 September 2017:  See also: Audits Highlighted Risk Assessment Weaknesses Prior to Ro-Ro Fatality, which goes on to discuss two marine accidents while towing that also involved risk assement failures.

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