Lawrence Cannon to the Press

[Widow]

Changes won't hurt aviation safety

The Leader-Post
Published: Tuesday, April 24, 2007

I want to respond to the article on aviation safety published in this newspaper on April 13, "Ending audits may be risky", that may have left Canadians with an inaccurate impression about the safety of Canada's aviation system.

Canadians should know and be proud to have one of the safest aviation systems in the world. Our enviable safety record is due in part to safety regulations that focus on accident prevention.

Canada's aviation accident rate continues on a downward trend. While this is an encouraging reflection on our world-leading safety record, it also means that we need to develop even more thorough methods for identifying and addressing potential safety problems as the industry continues to grow.

Contrary to the assertions made in your article, Transport Canada is not eliminating its safety oversight of the aviation industry. Transport Canada, through its program of inspections, audits, assessments and validations, continues to improve safety standards for the travelling public.

Changes to the Canadian aviation regulations make a safe aviation system in this country even safer by providing an extra layer of vigilance and protection to existing regulations, thereby helping to identify potential safety issues before they become problems.

Under this new approach, we are assessing safety at the system level rather than the operational level. This means that Transport Canada evaluates systems that operators put in place to ensure that employees are doing their jobs properly, that aircraft and aviation infrastructure are properly maintained, and that operators' overall safety practices and procedures remain among the best in the world. Operators must still comply with all the current regulations and standards. Transport Canada can and will continue to take enforcement action when necessary, because we remain committed to maintaining and improving upon our outstanding safety record.

The goals of these systems are to increase industry accountability, to instill a consistent and positive safety culture and help improve the safety performance of air operators, but leave the means of achieving that performance in the hands of industry management.

Safety management systems instill more accountability and a positive safety culture throughout the aviation industry, where management and employees can continuously work to enhance safety of the public by identifying and overcoming potential hazards.

Lawrence Cannon

Leader Post
Also in today's papers:

Ottawa open to revamped air safety bill

OTTAWA (CP) — Transportation Minister Lawrence Cannon now says he is willing to consider significant amendments to a bill aimed at making changes to airline safety regulations.

Cannon appeared before the parliamentary committee on Transport, Infrastructure and Communities. Several witnesses have told the committee that the proposed changes to the Aeronautic Safety Act will compromise airline safety in Canada.

The Federal Pilots Association have a survey indicating that most of its members believe a major aviation accident is likely to occur in Canada, and that the proposed changes will give more responsibility for safety to the airline industry and increase risk to the flying public.

The Association has also expressed concerns Transport Canada is decreasing the number of inspectors that do safety checks on commercial airliners.

Cannon has repeatedly said the proposed amendments and the use of Safety Management Systems (SMS) are intended to maximize existing airline safety, and that it will add a layer of safety.

"This is not a bill aimed at cutting jobs. This is a bill aimed at maintaining Canada’s position as a world leader in airline safety," Cannon said.

However, Cannon did say he would be willing to work with the committee in addressing safety concerns.

Richard Balnis, who represents 8500 flight attendants in Canada, says he’s encouraged that Cannon’s says he is open to amendments.

"In our view Bill C-6 is terribly flawed and it is in need of substantive amendment. In particular it needs an amendment to ensure there is proper regulatory oversight."

The Chronicle Herald

[CID]

I dunno about the flight attendant's representatives but at least on large pilot group is supporting SMS.

http://www.flightsafety.org/asw/apr07/a ... _p8-10.pdf

[Widow]

If you refer to the statements of Don Adamus, President of the Airline Pilot's Association, here: Committee Transcripts, then you will find that they agree that SMS must be complementary to government oversight - and they speak only from an airline point of view (most of us agree, that with airlines - who already have other risk management wheels in play - SMS is a great thing, the problem is with small ops).

All the witnesses before the committee with direct interest in the smaller ops have expressed concerns about SMS/oversight.

[Cat Driver]

I find it interesting how many posters here are for SMS at the 703 level of aviation.

If ever there was a license to cheat the rules for crooked 703 operators SMS is a dream come true.

Maybe all the crooked operators are no more?

[CID]

All the witnesses before the committee with direct interest in the smaller ops have expressed concerns about SMS/oversight.

So where do those 8500 flight attendants work? On Beavers and Otters?

Cat Driver,

Under the current system company executives are able to go from one failed unsafe shady operation to another with little or no accountability for the unsafe operating practices of the operation. That particular scenario gets played out over and over again. This is one issue that SMS is supposed to address

[Widow]

So where do those 8500 flight attendants work? On Beavers and Otters?

I didn't say those on airlines and large ops didn't have concerns. According to Balnis "Bill C-6 is terribly flawed and it is in need of substantive amendment. In particular it needs an amendment to ensure there is proper regulatory oversight."

Minister Cannon is now saying he is open to considering such an ammendment.

[Cat Driver]

Cat Driver,

Under the current system company executives are able to go from one failed unsafe shady operation to another with little or no accountability for the unsafe operating practices of the operation. That particular scenario gets played out over and over again. This is one issue that SMS is supposed to address

CID, please don't try and explain to me how commercial aviation works in Canada I have been in it for over fifty years and am quite familiar with how sleasy operators work and the lack of " effective " oversite by the regulator.

No matter how you slice it giving more flexibility in running their own operations will only make it easier for crooks to thrive.

If the new rules prevent sleasy operators from going back into the industry that would be great.

But how do they intend to enforce such a new policy, how do you control who really owns what?

[CID]

Cat Driver,

Can you explain how you think SMS will give operators more "flexibility"?

One of the cornerstones of SMS is the mandatory quality assurance system that encompasses all aspects of operations. Many small operators don't have such a system. How is this more "flexible"? The CARS require;

107.03 A safety management system shall include

(a) a safety policy on which the system is based;

(b) a process for setting goals for the improvement of aviation safety and for measuring the attainment of those goals;

(c) a process for identifying hazards to aviation safety and for evaluating and managing the associated risks;

(d) a process for ensuring that personnel are trained and competent to perform their duties;

(e) a process for the internal reporting and analyzing of hazards, incidents and accidents and for taking corrective actions to prevent their recurrence;

(f) a document containing all safety management system processes and a process for making personnel aware of their responsibilities with respect to them;

(g) a process for conducting periodic reviews or audits of the safety management system and reviews or audits for cause of the safety management system; and

(h) any additional requirements for the safety management system that are prescribed under these Regulations.

http://www.tc.gc.ca/CivilAviation/Regse ... t1/107.htm

That doesn't sound like more flexibility to me.

If the new rules prevent sleasy operators from going back into the industry that would be great.

But how do they intend to enforce such a new policy, how do you control who really owns what

Well, here's the way that works. If you're caught in condradiction to the regulations you're charged under the established guidelines. Except with SMS in place the charges won't stop at the AME or pilot or QA manager. The accountable executive is "accountable".

I won't pretend to predict if it will be 100% effective, but I think its an improvement if it does nothing but identify the guy who bankrolls the operation and takes him down.

[Widow]

Well, here's the way that works. If you're caught in condradiction to the regulations you're charged under the established guidelines. Except with SMS in place the charges won't stop at the AME or pilot or QA manager. The accountable executive is "accountable".

I won't pretend to predict if it will be 100% effective, but I think its an improvement if it does nothing but identify the guy who bankrolls the operation and takes him down.

I think many of us believe that TCCA is not doing this now - charging companies for non-compliance with the CARS - at least not uniformly or effectively. I find it hard to believe thath the small numbers listed on the website as having enforcement actions proceded with, are the only ops found in contravention of the CARs.

So if they aren't doing an effective job of enforcement now, how will it be better under SMS - where management has an extra layer of paper to hide behind?

[Cat Driver]

So if they aren't doing an effective job of enforcement now, how will it be better under SMS - where management has an extra layer of paper to hide behind?

Exactly.

And how do you prevent unethical management from using intimidation to keep the troops in line?

[sky's the limit]

Leaving the "industry management" to oversee the operators is nuts. Could it work at a 705 level? Possibly, but at the Air Taxi level, I think it's nuts. The Foxes will indeed be looking after the Hen House....

It's hard enough to find decent employers with decent machinery, and decent pay as it is - this is not going to help.

But hey, we "have one of the safest..... yadda, yadda, yadda"

stl

[CID]

widow,

All good questions if you beleive the assumptions you've stated. I think the system in Canada overall is safe and that enforcement is effective.

Not every incident is worthy of enforcement action. If that was the case there would be 20 or 30 fines issued every day. Having said that, TC investigates many incidents each day across the country to determine if additional action or enforcement is appropriate.

A simple pilot error due to extraordinary circumstances that momentarily reduces the level of safety slightly should not be subject to enforcement action. Its much more appropriate and effective to discuss the indicent and offer counsel or training.

You and I have been at odds regarding the overall safety of the industry and that's OK. I think we've learned alot from each other and I hope you don't feel I've been adversarial for the sake of argument. If we have any common ground I think we agree that the 703 sector has the worst safety record in the system.

So is that because the regulator is so bad at detecting problems or is it because the operators are so good at hiding them? Problably a little of both but in my experience, there are a handful of crooks who's names keep popping up when I discuss (offline) crooked 703 operators.

They like to bankroll the operation and collect a bunch of easily manipulated patsies to runs things for them. There are plenty available. They are typically guys who have serious contempt for authority and the regualtions usually because they don't understand them. They assign DOM, QA, CP jobs to young guys who are offered big money or old bitter drunks that have nowhere else to go.

When an accident finally occurs or an audit uncovers serious issues, the guy with the money hangs all the guys responsible for safety and runs.

These guys are often smart enough to make sure many of the larger assets are in their own names rather than in the company name so they have some equity to liquidate to start again a few months later.

SMS should go a long way in making sure the guy with the money accountable and prevent such a collection of crooks to come together in the first place.

So if they aren't doing an effective job of enforcement now, how will it be better under SMS - where management has an extra layer of paper to hide behind?

Where is this extra layer of protective paper you speak of? I'm sorry but I sincerely don't understand your statement.

[Cat Driver]

Lets examine this opinion.

They like to bankroll the operation and collect a bunch of easily manipulated patsies to runs things for them. There are plenty available.

I would tend to agree with you there CID.

They are typically guys who have serious contempt for authority and the regualtions usually because they don't understand them.

This has not been my observations of the industry as a whole, in almost every instance that I can recall the " Patsies " tended to be young relatively inexperienced easily manulipated people who accepted the position for the title for the title, and to further their careers.

They assign DOM, QA, CP jobs to young guys who are offered big money or old bitter drunks that have nowhere else to go.

In many instances this may be true.

May I suggest the fault for such situations should lie with the screening process before approving these individuals and the downstream monitoring of their performance?

My above comments are arrived at from having held these positions in 703 / 704 / 705 operations.

[pushyboss]

Part of the issue here is the wide variations in 703 operators. 703 encompasses "mom and pop" operations flying one aircraft for summer ops only but also encompasses much larger operations flying much larger and sophisticated aircraft. So to imply that an entire class of operators are sleasy or operating outside of the law (based solely on their type of operation) is gossly misleading. Our operation is 703 and operates 6 turbine aircraft 5 of which are King Airs.

SMS will not allow us any greater flexibility, in actual fact, SMS forces us to be more restrictive in our operation and also forces ownership to be part of the risk/hazard analysis. Under the current system an operator/owner has no liability (other than losing his business) should an accident occur. Under SMS the owner/accountable executive holds greater liability and the penalties can be substantially greater.

I find it vaguely amusing that the biggest opponents to SMS are the ones that have no experience with SMS or even with commercial aviation. Some of you seem to have taken the position that operators are constantly looking for ways to circumvent the regulations and that we are content to put our passengers/customers lives knowingly at risk. Nothing could be further from the truth. All of the operators I work with are keenly aware of their responsibility for the safety and well being of their passengers. Are their sleaze bag operators out there? Sure there are. But those operators will operate outside the regulations whether we are SMS or not. To suggest that TC should basically park themselves on top of these operators and invigilate them daily is unworkable.

SMS does not allow me as an operator to self regulate. TC will still oversee our operation. However, as opposed to the current system, TC will audit my SMS and ensure that our risk management stategies, our hazard reporting systems, our risk/hazard mitigation practices, and our non-punitive reporting systems are in place and effective.

[Widow]

A simple pilot error due to extraordinary circumstances that momentarily reduces the level of safety slightly should not be subject to enforcement action. Its much more appropriate and effective to discuss the indicent and offer counsel or training.

Agreed.

So is that because the regulator is so bad at detecting problems or is it because the operators are so good at hiding them? Problably a little of both but in my experience, there are a handful of crooks who's names keep popping up when I discuss (offline) crooked 703 operators.

They like to bankroll the operation and collect a bunch of easily manipulated patsies to runs things for them. There are plenty available. They are typically guys who have serious contempt for authority and the regualtions usually because they don't understand them. They assign DOM, QA, CP jobs to young guys who are offered big money or old bitter drunks that have nowhere else to go.

My belief is that TCCA should recognize these things - the use of "inferior" or inexperienced persons in positions of authority, the return of unsafe ops under a new name, etc. It is inappropriate for them to only inspect if a complaint is received - especially since there is no real protection for whistleblowers - CAIRS is garbage (in my own experience). I do not know much about the TSB SECURITAS, but expect it to be similar in its "confidentiality" to CAIRS. Despite SATOPs recommendation that ALL air taxi ops be inspected regulary, TCCA only increased the inspection process for aircraft with two engines. Why should an aircraft with fewer people have a lower expectation of safety than one with more? For goodness sake, the "Annual Airworthiness Information Report" doesn't even "guarantee" airworthiness - the most recent one in the ATIP on CGAQW doesn't even have the right float or prop model listed! We all know there are planes up there, carrying passengers, which should not be in the air. What happened to TCCA inspectors actually looking at the aircraft, and not just the paperwork?

I also believe that when someone runs businesses in more than one industry, and an accident caused by unsafe practices costs a life, that the companies in the other industry/industries should be inspected immediately for similar problems. In our case, had TCCA been aware of MJM's logging company and the cause of that death in 2003, and thus inspected MJM for similar problems (lack of maintenance, unqualified maintenance, etc), my husband may still be alive today. This is a problem that I believe is exacerbated by the provincial/federal jurisdictional divisions for workplace injury/death accident investigations.

So I, and many others, do not agree that TCCA is currently inspecting/enforcing appropriately (let alone interpreting the CARs effectively to begin with) for 703 ops. If that inspection/enforcement is not effective now, and there are no plans to improve/change the current methods, then, in my opinion, SMS will only give the shady operator (and his "inferior" employees) a new curtain to hide behind. As far as I can tell, inspections are mostly begun due to something on paper. Shady operators are very effective at hiding behind paper - they can and will continue to lie.

If a shady op, like the one that killed my husband, is not reprimanded in any way (like ours), not only will they keep doing what they are doing, but it gives the impression that TCCA is ok with that, and other shady ops can keep on doing what they are doing because there are no repercussions.

[snaproll20]

The 107.03 CARS that CID refers to is like an English literary assignment at a University.

It is flowery garbage, enabling fertile imaginations to concoct totally fictional but believable stories about how things are actually done.

What I mean is every shady company out there will produce a ton of contradictary bafflegab that their lawyers can submit as "evidence of due diligence", supposing their nasty butts are everdragged into Court.

Fact is, TCCA has a miserable record of pursuing and convicting wrongful characters. It is so bad, one is forced to wonder about possible pay-offs. The least a person can suspect is that TCCA has no will, or else is incompetent in getting the job done.

And people continue to die.

We do not need SMS legislated into our lives. The good people already practice the theory.

TCCA supposedly already has the hammer to deal with bad companies, so why don't they use it?

Fact of the matter is, instead of launching SMS, they only needed to write into the CARS that "accountable executives" will be made answerable to any prosecutions launched by Enforcement.

At the present time, as noted previously, the nasty owners hire unwitting management people who try to cope with difficult circumstances and then get the full brunt of any Enforcement action.

Again, merely write into the CARS that the Owners will be made legally liable, and the job is done. One paragraph.

Evidence supplied by employees of undue pressure to fly in contravention to the CARS............."Mr, your Operational Certificate is revoked."

But no, that would be too damned easy, wouldn't it?

[Widow]

The power to hold "an accountable executive" responsible has already been created by Bill C-45 - the ammendment to the criminal code which holds company/corporations responsible for negligent actions, or inaction.

The fact that Bill C-45 has hardly been used at all in any industry, and never in aviation - is a whole other problem.

[CD]

The power to hold "an accountable executive" responsible has already been created by Bill C-45 - the ammendment to the criminal code which holds company/corporations responsible for negligent actions, or inaction.

The fact that Bill C-45 has hardly been used at all in any industry, and never in aviation - is a whole other problem.

I had posted this some time ago in response to a similar discussion that we were having...

Can anyone give me examples of TC holding management accountable?

The regulatory structure to recognize the concept of management accountability is just now starting to be put in place. Here is some information on the implementation:

BILL C-6: An Act To Amend The Aeronautics Act
Proposals to Amend the Aeronautics Act

Initially, I recall that there was to be some individual liability associated with these proposals but I believe that this was modified or removed following consultations... The answer may be in that second link as it has the history of the Aeronautics Act proposals (see the section on Enforcement s.8.4-8.7)...

[CID]

We do not need SMS legislated into our lives. The good people already practice the theory.

Umm...

Snaproll20, that statement suggests that the not-so-good operators need to do what the "good people" (the respsonsible people) already do. SMS will bring the aviation industry into the 21st century in line with every other major industry that has embraced SMS.

The text in the reference I provided is pretty straight forward and typical to guidance used by airlines (and other industries) that have had a formal and effective QA system.

Fact is, TCCA has a miserable record of pursuing and convicting wrongful characters. It is so bad, one is forced to wonder about possible pay-offs. The least a person can suspect is that TCCA has no will, or else is incompetent in getting the job done.

Really? They have a miserable record? Can you cite examples? I think "miserable" is a pretty strong word.

Widow,

I think one of the fundamental differences between you and I lie in the fact (if I read you right) that when it comes to slimey operators, TC is an enabler. Snaproll20's statements seem to support you too.

I think slimey operations are the result of slimey people. Regulations are funny things. Almost as soon as a new one appears, someone is thinking of ways to get around it. So I suggest that if rules are being broken, then there is a proliferation of corruption among the operators and especially among west coast 703 operators.

Why is that? Maybe TC should just shut down the whole west coast until they do a study? Not practical? I agree. They are trying to make things better through the only tool they have. Regulation. West Coast 703 operators are fighting back with the only tool they have. Corruption, contempt and criminal activity.

I don't think TC is an enabler. Its the embattled regulator.

[Widow]

I have to keep going back to SATOPs, Transport Canada's own evaluation of the air taxi industry. There were several recommendations which were made, specific to TCCA oversight which were either not acted on at all, or action was halted.

Here are some of those recommendations. Some of them may have been adopted, and I am not aware.

Pilots can be pressured by management to take a flight in poor weather conditions or with an overloaded aircraft or with an unserviceable aircraft fearing dismissal if they don't take the trip. Many pilots are unaware of the Canada Labour Code, Part II or the Occupational Safety and Health (OSH) Regulations and the methods of recourse that are open to them if they feel they have been unfairly treated by an air operator or if they refuse to work because of dangerous work conditions. Air operators should also be aware of their rights and the rights of their employees as outlined in the Canada Labour Code, Part II and the OSH Regulations.

SR 36 - Recommend Transport Canada promote awareness of the Canada Labour Code, Part II and the Occupational Safety and Health (OSH) regulations to the aviation industry.
IA 36 - Recommend air operators and pilots educate themselves on the Canada Labour Code, Part II and the OSH regulations.

When a pilot is being paid by the mile or the hour flown, or is being paid only for completed flights, it puts pressure on the pilot to fly as many hours as possible and to complete the flights. These methods of remuneration have a direct and negative effect on the pilot's decision making, especially in seasonal operations where there are only a few weeks or months to work. Some operators offset this pressure by paying their pilots a fixed salary. Others require the client to pay for the flight time if the client wants to just "take a look" at the weather and the pilot doesn't complete the flight.

SR 37 - Recommend Transport Canada investigate a means to require air operators to remunerate pilots in a way that eliminates the operating pressures associated with the method of payment.

IA 37 - Recommend air operators and pilots acknowledge the negative effect that the "pay-by-the-mile" method of payment can have on safe operational decision making. Recommend air operators and pilots make decisions based on safety, not remuneration and that air operators consider other methods of remunerating pilots.

Transport Canada's audit and inspection methodology was criticized as not being sufficiently operations-oriented and not occurring frequently enough. Inspections and audits that check only the paperwork don't give a true perspective of the actual operation. As an example, since aircraft inspections are done in a stationary aircraft rather than when the aircraft is in flight, the inspector can only confirm that the instruments are installed, not that they are functioning. If Civil Aviation inspectors performed "inflight" inspections, especially now that industry has more delegated authority to perform pilot proficiency checks, it would provide Transport Canada with a better understanding of operating conditions, operational practices and pressures. Inflight inspections should be conducted in both single- and multi-engine aircraft.

SR 58 - Recommend Transport Canada conduct more operations-oriented audits and inspections.
SR 59 - Recommend Transport Canada conduct in-flight inspections in Air Taxi aircraft.
Transport Canada was criticized for providing sufficient notice of an upcoming audit that the operator had time to get the paperwork in order before the auditors arrive. Less notice would give Transport Canada a better indication of the air operator's actual operation. Also, more random inspections should be done, especially during the operators' busy season. Pilots commented that Transport Canada inspectors rarely conduct inspections on job sites, that the inspections are limited to ramp inspections or audits. Non-compliance with the regulations was thought to occur more frequently in areas removed from main airports where inspectors are less likely to conduct random inspections. There is also the perception that regulatory compliance is not applied uniformly among operators and that some operators have an obvious disregard for the regulations but Transport Canada is either unaware or chooses to overlook this.

SR 60 - Recommend Transport Canada conduct more random audits and inspections.

SR 61 - Recommend Transport Canada provide more regulatory compliance presence, especially in northern and remote areas.
Transport Canada was also criticized for not conducting follow up of audit findings. When audit findings are not rectified by the air operator, the unsatisfactory operating condition continues and often the deficiencies are noted in the subsequent audit.

SR 62 - Recommend Transport Canada ensure all audit follow-up is completed.

IA 62 - Recommend air operators ensure all audit findings are rectified.

Air Taxi operators and pilots feel that air carrier inspectors do not have the appropriate background to understand VFR issues and issues that are specific to certain operations or regions. For example, the west coast operators and pilots felt that there was no one in Commercial and Business Aviation, Pacific Region who had recent experience in the unique operating conditions of west coast float operations. All Transport Canada inspectors must possess an Airline Transport Pilot Licence in order to qualify for the position. Often this means that the inspector has not been flying in VFR operations for some time before being hired by Transport Canada. The same comments were received from operators and pilots throughout the other Regions. It was suggested that Transport Canada should have inspectors on staff with strong VFR backgrounds who could deal sensitively with VFR issues. Many negative comments were received about Transport Canada hiring inspectors with no commercial operating experience.

SR 63 - Recommend Transport Canada Regional Commercial and Business Aviation inspector personnel are more representative of the demographics of the aviation industry.
The attitude of some Transport Canada air carrier inspectors was criticized as being arrogant and uncooperative. A more cooperative attitude between inspectors and the industry will enhance the working relationship and eliminate the "we vs. they" mentality. Since they are part of the aviation system, air carrier inspectors should be perceived as being approachable and a good resource for information, not just as the regulator who is interested in catching pilots and operators who are breaking regulations. Industry has no recourse if they are concerned about a particular inspector's behaviour.

SR 64 - Recommend Transport Canada establish a conflict resolution program where members of the aviation industry can confidentially report problems with individual Civil Aviation inspectors.

When questioned about the safety of air taxi ops and changes made with regard to these recommendations, TC expounds on how the accident rate has improved significantly over the last ten years. While this is true, it is also true that the accident rate accross the board (all types of ops) have improved - due undoubtedly, to the improvements in technology more than anything else. If you refer to Implementation Status - Flight 2005 you will find that accident rates for 703s from 2001 to 2005 are 5.21, 5.49, 4.98, 6.02 and 5.78. Now, although it is noted at the bottom of the table that the accident data source is the TSB, the rates shown here TSB - Air Occurence Statistics for 2001-2005 are 4.9, 6.0, 5.4, 6.6 and 4.7. I am very confused about why these figures are different, and rather significantly so.

[CID]

While this is true, it is also true that the accident rate accross the board (all types of ops) have improved - due undoubtedly, to the improvements in technology more than anything else.

There really haven't been any significant technological advances that would contribute to saftey in the 703 sector in the last 10 years. Especially in Canada where some of the safety system that are mandated in other parts of the world aren't mandated here.

TAWS and TCAS are good examples. These are not required by 703 Ops or any other Ops in Canada. Neither would help VFR flights.

The introduction of GPS navigation was the single most significant contribution to navigation and has been with us since for over 10 years but again really doesn't mean much to VFR operators.

Engines and structure haven't changed much at all either. There really aren't many what you would call "new" designs in use to any great degree in Canada. Yah, there are lots of PC-12s around but they use fairly old technology when it comes to systems, engines and structure.

In my opinion, the accident rates are tied much more to training than anything else. Maybe the Human Factors training mandated for AMEs by TC is paying off a little. You may remember all the outrage from the industry when that was introduced.

Your question about the discrepencies between the TSB and Implementation status report is a good one. I'm not surprised though as it is typical that different agencies calculate statistics differently to meet their particular "needs".

The definition of accidents and incidents vary between reports. To tell you the truth, I don't think there is enough data in those 5 years to establish a trend anyway. In our relatively small industry, all it takes is a couple of accidents to spike the numbers.

[Widow]

CID, the point is that accident rates have improved across the board over the last 10-15 years, but the air taxi rates remain considerably higher than any other type of commercial ops.

Have any of the above recommendations from SATOPs been adopted?

[pushyboss]

CID,

TAWS will be required in 703 operations later this year (the implementation date keeps getting pushed back) in all multi engine aircraft with more than 6 passenger seats.

Our 703 operation has upgraded several of our King Airs with TAWS, and the remainder are scheduled to be done later this summer. We are also upgrading our entire King Air fleet with WAAS as well. This is why it bothers me that many of these discussions lump all 703 operators together. A 703 operator is no more inherently unsafe than a 705 operator is inherently safe.

[Widow]

When has anyone lumped all 703's together? I think a problem is that there has been very little change in the way shady ops are dealt with, and this reflects badly on both TC and the accident rates - one bad apple can spoil the lot (or at least its' reputation).

No one has said all 703s are shady. No one has said all TC folk are corrupt or ineffective.

But the ones who are need to be dealt with. We, more importantly you in aviation, can't keep blaming the pilot without dealing with the problems which put him/her in the position of having to make a decision he/she shouldn't have had to make at all.

[Cat Driver]

But the ones who are need to be dealt with. We, more importantly you in aviation, can't keep blaming the pilot without dealing with the problems which put him/her in the position of having to make a decision he/she shouldn't have had to make at all.

There are a lot of people in aviation who should hang their heads in shame when an outsider to this industry has a better grip on reality than a lot in aviation who bury their heads in the sand.

widow you are one bright lady, my hat is off to you.