Monday, April 1, 2013

Rebuttal to: Danger Overhead Part 1: Transport Canada

Danger Overhead Part 1: Transport Canada cuts may endanger small air operators

Safety of commercial flights called into question

There were three separate Canadian Publication that posted articles related to Safety Management Systems, SMS, Today!. It almost looks like a frontal assault on SMS! The main theme of each article is pretty much the same. SMS can not work for small carriers and that Transport Canada is not doing it's job to properly regualate them. All these articles trot out tradgic accidents from the past to set the public mood. These accidents were tragic and cost lives, but, we must truly investigate what the root causes are for each one. 

These accidents are tragic and something needs to be done to prevent and/or mitigate them. The article goes on to suggest that the Transport Canada’s move to Safety Management Systems, SMS, may have contributed to the small operator’s safety issues. It is important to note that ALL the small operation accidents happened NOT under SMS. SMS is not required for small operators at this time. It will be in the future. SMS is tailored to the size of a company.

So the idea that small operators can’t implement SMS because their are not Air Canada or Westjet is irrelevant. SMS can be easily implemented by small operators, with the right training, and is not as hard to implement and maintain as most claim. In fact, the article provides more of an incentive for Transport Canada to mandate SMS to small operators. Statistics show that it does increase Safety to the Public and allow these operators to gain better control of their operations. Yes, Transport Canada is facing resource issues but, their surveillance program, under the Staff Instruction SUR001, does an excellent job of revealing Safety issues in any operator with powerful sampling techniques. 

Transport Canada’s Surveillance program uses a “Systems Approach” to oversight. The concept in a nutshell is this. The enterprise management is responsible to make sure all their operations are under “Control.” What is Control? The company has and is following standard operating procedures, auditing those processes to make sure people are following procedures, performing internal corrective actions on hazards, and continuously monitoring and improving it’s system processes. 

Yes, Transport Canada made some mistakes in it's implementation of SMS for the 705 Carriers. We must remember that no other country in the World has mandated SMS for thier carriers, so Transport Canada was plowing the new ground here. I believe that have first hand experience in what works and what doesn't work better than any other regulator. 

You can not condemn Safety Management Systems if it not tried! Statistics don’t lie, SMS, when implemented properly will make a company safer. Will it prevent an accident? No, but the system will identify when things are going “Out of Control” BEFORE and accident. I my career dealing with the US Military, NASA, Transport Canada...every accident has a trail of something going out of control before the accident. SMS can catch the hole before making through the entire “Swiss Cheese.” 

Illustration of the "Swiss Cheese" model that shows an alignment of the holes that cause and accident. If a company that has SMS will have controls on all their Processes. This will seal each hole in the processes that lead to an accident. 

As the article suggests; “Gord Marshall thinks Transport Canada will have to abandon altogether its hopes for eventually having SMS at air taxis and smaller commuter operators and restore — even boost — traditional front-line inspections.” Is a mistake and going backwards!

NOTE: Sol and I are the Facilitators to all Transport Canada Inspectors for their Surveillance Procedure Training Program as well as the consultants to Transport Canada's Quality Assurance component of the Safety Management System. We also have consulted to over 200 private aviation enterprises, much of which are small operators. 

your thoughts...............


  1. It becomes simpler to operate safe with an SMS in place than without SMS, simply because SMS requires planning. When one fails to plan, one makes a plan to fail.

  2. I suggest we scrap the term SMS. Then add some additional requirements to 703 and 704, such as hazard and incident reporting, risk analysis, safety cases, QA for flight ops. Simplify it. Some of the components are so worthwhile but unmanageable as an "SMS" by smaller operators.

    Operators will never be able to "win" because Inspectors interpret the SMS requirements differently, so it is always a moving target. With insufficient oversight of the Inspectors, implementation of SMS in 703 and 704 in the TC's current state (insufficient financial and human resources), in my opinion, will be a nightmare.

    1. Glenna, Thank you for your comments. I think all will find them interesting.

  3. Not just governments are requiring SMS. Many larger companies that hire outside aviation services are requiring SMS or they won't hire them. Why? Because it makes a company institute control of its processes and procedures proactively.

  4. Many companies that have instituted SMS have also stated that they have seen a greater profit margin. The natural result of control of processess is much more effeicient outputs. Another financial benefit of instituting SMS is this. Many insurance companies will LOWER premiums to companies that can prove an effective Safety Management System. In addition to the added Safety aspects of SMS, I am sure there are many companies that wouldn't mind saving MONEY!!!

  5. Yes. That's true; however, the SMS requirements by clients are different in depth than what (some?) TC's Inspectors want. I agree that SMS is a good thing; however, the problem is with TC and the varying interpretations and requirements by Inspectors.

  6. Ah Yes, You hit the nail on the head. As you know Sol and I are still teaching the Surveillance Procedures Course for the remaining TC inspectors. The ENTIRE purpose of the course is to STANDARDIZE the approach to Surveillance so that every inspector treats every company the SAME! Unforunatley, a lot of the inspectors we teach forget the standard and go back to their old ways. Believe me, the inspectors are taught to handle small operators differently than larger ones. The procedure is the same but, the application is commensurate to the size of the enterprise.

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