ACCIDENT COUNTS CANNOT BE USED ALONE

 ACCIDENT COUNTS CANNOT BE USED ALONE

By OffRoadPilots

During the 109 complete months from August 2016 through August 2025,

the combined dataset records 1,269 commercial aviation accidents in

Canada and the United States. Of these, 625 occurred in Canada and 644

occurred in the United States. This represents a remarkably even

geographical distribution: approximately 49.3 percent occurred in Canada

and 50.7 percent in the United States. The combined average was

approximately 11.6 commercial accidents per month. These figures should

not be interpreted as accident rates because the workbook does not

contain exposure data such as departures, flight hours, passenger miles,

aircraft movements, or commercial fleet utilization. They measure

occurrence frequency only.

Commercial aviation represented approximately 9.8 percent of the 12,965

total aviation accidents recorded across the combined dataset during

these 109 months. General aviation therefore accounts for the substantially

larger portion of accident frequency. However, commercial aviation

remains operationally important because individual commercial accidents

can expose more occupants, employees, passengers, customers, cargooperations, and members of the public to consequences. Accident

frequency alone therefore provides an incomplete measure of commercial

aviation risk. Safety management should examine both how often

accidents occur, and the potential severity associated with individual

events.

The monthly distribution demonstrates considerable variability rather than

a stable fixed number of commercial accidents. The highest monthly total

in the comparable period occurred in July 2019, with 26 commercial

accidents. August 2023 recorded 25, May 2017 and July 2017 each

recorded 24, August 2024 recorded 23, and July 2025 recorded 22. Several

of the higher-frequency months occur during the summer operating

season. This pattern deserves attention, although the dataset alone cannot

establish causation. Increased seasonal flying, aerial work, flight training,

tourism, wildfire-related operations, agricultural activity, remote operations,

weather exposure, and higher aircraft utilization could influence summer

frequency. Exposure information would be required before concluding that

summer operations have a higher accident rate.

Fatality information

demonstrates why

frequency, and severity

must be analyzed

independently. Across the

comparable period,

commercial aviation

accidents resulted in 475

recorded fatalities: 191

associated with Canadian

commercial accidents and

284 with United States commercial accidents. The monthly average was approximately 4.4 commercial aviation fatalities, but this average is strongly affected by relatively infrequent high-consequence events. 

A month with numerous accidents can have comparatively few fatalities,

while a month with fewer accidents can produce a substantial fatality total.

January 2025 is the clearest example in the workbook, with 14 commercial

accidents but 73 fatalities. July 2019 recorded 26 commercial accidents

and 36 fatalities.

This variability demonstrates a central principle for Safety Management

Systems: accident counts cannot be used alone as the measure of safety

performance. A declining number of accidents does not automatically

establish that underlying operational risk is declining. Conversely, an

increase in reported occurrences does not necessarily mean the system

has become proportionately less safe. Safety performance must consider

severity, exposure, operational context, precursor events, hazards,

effectiveness of risk controls, and whether adverse trends represent

common-cause or special-cause variation.The annual figures also illustrate fluctuation. The dataset records 170 commercial accidents in 2017, 132 in 2018, 158 in 2019, 107 in 2020, 127 in 2021, 126 in 2022, 139 in 2023, and 144 in 2024. 

The 2020 reduction is

particularly notable but should not automatically be interpreted as an

improvement in system safety because aviation activity was substantially

disrupted during that period. Without normalizing accident numbers

against commercial activity, conclusions concerning improvement or

deterioration would be unreliable. The appropriate question is not simply

how many accidents occurred, but how many occurred relative to the

amount and type of aviation activity conducted.

The data provides valuable

strategic information.

Commercial accident

frequency persists

throughout the entire period

rather than disappearing as

technology, regulation,

aircraft reliability, training

systems, and safety

programs evolve. This

reinforces the principle that aviation safety is a continuously managed

process. Past safety performance does not guarantee future performance.

Each accident represents evidence that combinations of hazards, operational conditions, human factors, organizational factors, technical failures, environmental conditions, or ineffective defenses can still

penetrate the aviation system.

For commercial operators, the strongest application of this dataset is

therefore proactive and predictive Safety Management System analysis.Operators should not wait for an accident before identifying deterioration.

Flight operations, maintenance control, dispatch or flight following, ground

operations, training, fatigue management, weather decision-making,

runway events, unstable approaches, rejected takeoffs, diversions,

mechanical interruptions, loading errors, towing events, near misses, and

procedural deviations can provide leading information long before they

contribute to an accident. Trending these indicators monthly can reveal

changes that accident statistics alone cannot detect.

The combined data shows a commercial aviation system with relatively low

accident frequency compared with the total aviation accident population,

but with continuing exposure to occasional high-severity outcomes. The

principal safety lesson is therefore not that commercial aviation is either

becoming safe or unsafe based on monthly totals. Rather, commercial

safety requires continuous monitoring of frequency, severity, exposure, and

precursors.

A Safety Management System should investigate significant monthly

variation, identify special-cause changes, determine organizational and

operational root causes where appropriate, and verify corrective actions

through Safety Assurance. The objective should be continuous control of

risk rather than achievement of an assumed final state of safety. Canada

and the United States have mature aviation systems, but this dataset

demonstrates that commercial aviation safety remains dynamic. Effective

SMS programs must therefore continually learn from accidents while

placing greater emphasis on detecting the conditions that precede them,

allowing organizations to intervene before those conditions develop into

the next serious or fatal accident.

OffRoadPilots

SIMPLE OR COMPREHENSIVE CAP

SIMPLE OR COMPREHENSIVE CAP

By OffRoadPilots

Some time ago, a comprehensive series of Corrective Action Plans (CAPs)

was developed for an airport in response to findings identified by Transport

Canada during a regulatory oversight activity. Each corrective action plan

was prepared using the principles of the aviation Safety Management

System (SMS), conforming to Advisory Circulars, with the objective of

addressing the root causes of every finding, strengthening regulatory

compliance, and establishing sustainable processes that support

continuous safety improvement. 

Rather than treating the

findings as isolated

deficiencies, each CAP

examined the underlying

human factors,

organizational factors,

supervision factors and

environmental factors that

contributed to the

observation. Every finding

was individually analyzed,

documented, and linked to

specific corrective actions, assigned responsibilities, implementation

timelines, verification methods, and long-term monitoring activities. This systematic approach ensured that corrective actions addressed not only immediate compliance concerns but also the organizational processes

necessary to prevent recurrence.

The corrective action plans emphasized compliance with the Canadian

Aviation Regulations (CAR), Transport Canada guidance material, Airport

Operations Manual, and their Safety Management System policy andmanual. Each finding was supported by documented evidence demonstrating how the proposed corrective actions would restore compliance while improving the effectiveness of airport management

systems. Where appropriate, procedures, manuals, inspection processes,

reporting mechanisms, documentation controls, training programs, quality

assurance activities, and management oversight functions were reviewed

and enhanced to create lasting improvements rather than temporary

solutions.

Corrective Action Plans

incorporated recognized

Safety Management

System principles

including hazard

identification, risk

assessment, root cause

analysis, corrective action

implementation,

management

accountability, employee

participation,

documentation control, internal auditing, performance monitoring, and continuous improvement. Corrective measures were designed to strengthen safety culture by ensuring that operational personnel clearly understood their responsibilities and that management maintained

effective oversight of regulatory compliance.

Every corrective action included measurable deliverables and defined

completion criteria. Verification activities identified how management

would confirm that corrective measures had been successfully

implemented and remained effective over time. Follow-up inspections,document reviews, operational observations, internal audits, training

verification, and performance monitoring were incorporated to

demonstrate that compliance would be maintained after implementation

rather than achieved only during the initial correction period.

Corrective Action Plans

also recognized that

sustainable regulatory

compliance depends upon

effective management

systems rather than

isolated technical fixes.

Consequently, significant

attention was given to

improving communication,

documentation,

accountability, competency,

reporting processes, record management, operational consistency, and

quality assurance throughout the organization. These improvements were

intended to strengthen organizational resilience and reduce the likelihood

of future regulatory findings.

Although the corrective action plans comprehensively addressed each

individual finding, Transport Canada subsequently rejected the submission.

The rejection did not arise because the findings had been ignored or left

unresolved. Instead, the submission reflected a level of technical detail,

analysis, supporting evidence, and comprehensive documentation that

exceeded what Transport Canada expected within the corrective action

plan format. The plans provided detailed explanations of root causes,

implementation strategies, verification methods, management

responsibilities, and continuous improvement activities for every finding,resulting in documentation that was significantly more comprehensive than

the regulator anticipated for the CAP review process.

The experience highlighted

an important distinction

between preparing a

technically complete

corrective action plan and

preparing a regulatory

submission that aligns

with the reviewing

authority's preferred

format and level of detail.

While the CAP

demonstrated extensive

analysis and commitment to long-term compliance, regulatory reviewers

generally require concise documentation that clearly identifies the finding,

the corrective action, the responsible individual, implementation dates, and the method used to verify effectiveness. Supporting technical analysis and detailed implementation documentation are often better maintained as internal working documents rather than included within the primary CAP

submission.

Despite the rejection, the work completed represented a significant

investment in organizational safety improvement. The analysis established

a strong foundation for strengthening airport operations, improving

documentation, clarifying responsibilities, enhancing quality assurance

activities, and supporting a proactive safety culture. The corrective action

plans also demonstrated management's commitment to addressing the

intent of every regulatory finding rather than simply achieving

administrative compliance.These Corrective Action Plans therefore represent a comprehensive example of applying Safety Management System principles to regulatory

compliance. By addressing each finding individually, identifying root

causes, implementing measurable corrective actions, assigning

accountability, and incorporating verification and continuous improvement

processes, the CAP provided a robust framework capable of supporting

long-term operational safety and regulatory compliance. Future

submissions can benefit from the same technical rigor while presenting

corrective actions in a format more closely aligned with Transport

Canada's expectations for regulatory review, allowing the underlying

technical analysis to remain available as supporting documentation when

requested.

OffRoadPilots

This post is based on a true story and has been written using information

obtained from reliable sources.