SMS From Another Perspective

[george sugar]

Would you rather have an accident, or prevent the accident altogether? If it is the latter, then you should be an advocate for SMS. Any objections to SMS then become not a matter of foundational principles, but rather questions of personalities, methodologies and any other axes in the tool shed we care to grind. If we can get consensus on this basic premise, then we are most of the way to being safer as an industry.

For whatever reason, Transport Canada chose to be in the forefront of requiring SMS. The people that made that choice had a particular vision for how it should be implemented, and arguably this vision should have more thoroughly developed, communicated and planned than it has been. Point conceded. However, the foundational principles remain valid no matter why we think Transport did it, whose idea it was, nor what transpired during our dealings with Transport in the past. And as the concept has had time to mature, SMS is evolving and now being rolled out in a very orderly and effective fashion, and is accruing real value to those companies that have put it in place.

The basic idea of SMS is that we as individuals and companies are responsible for our own safety. Through proven methodologies customized to our particular circumstances, we are given documented and formal processes to see where we are, where we want to be, and the means to measure how well we are approaching and maintaining those goals. To the many who have complained about intrusive oversight, one would think that this would be just what we have wanted; so why all the resistance?

SMS does not mean that Transport oversight will simply go away. Rather that oversight will now measure how well we perform under these increased responsibilities we have asked for all these years. Many see SMS as some sinister plot to deflect responsibility, but if anything Transport will be under even more scrutiny as we shift to this new regime; everyone is suspicious of change, even if it is for the better, but is that a valid excuse for not improving?

They will not hand over the keys so easily though. Until a company demonstrates that they are willing and able to accept this responsibility, they will not be certified. The implications of this are that some operators will not be permitted to continue to operate. This will be the sharp point for the employees that currently complain about unsafe conditions; you may be forced to seek other employment because the operator you work for, and have complained about, will have its certificate pulled. Gone will be the pressure to press on regardless in an unserviceable airplane in marginal weather, but perhaps this will be replaced by other more personal pressures.

SMS as an idea is not new; it has been standard practice among large multi-national industries for decades. Quality control and quality assurance are widespread business concepts, and indeed aircraft maintenance organizations have operated to these standards for some time. SMS is also an idea whose time has come to aviation whether we like it or not; IATA requires an approved SMS as a condition of membership, and the FAA is well on its way to requiring it in more or less the Transport Canada form as well.

In Canada, given our broad spectrum of aviation activities, we have to ask if safety is a consistent concern across all facets of aviation. Is not someone who pays to fly on an Otter to Tofino entitled to the same level of safety as an Air Canada passenger to Osaka? Is one life any less valuable than another, and is one life any more valuable if it is put at risk in the company of hundreds rather than just 18?

SMS is here, and it is a reality of the present day and the future in our industry. Just as us stick-and-rudder old-timers need to get over the evils of automation and glass cockpits, we also need to accept that this is the way our industry is going. Just as the flight deck has turned into an exercise more in management and strategy rather than tactics, the safety culture of airlines is becoming more forward-thinking and predictive, rather than reactive and regretful for the things we should have done to prevent an accident. To resist such a change seems irrational, and we need to get over the nit-picking and lend our expertise and experience to the opportunity that Transport Canada has thrust upon us.

I look forward to your comments and further discussion.

[Clearwater]

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[Widow]

George Sugar,

How much objection is there to the concept of SMS? I haven't heard any. Who would object to an extra layer of protection where everyone involved does their part?

The objections I've heard are all related to Transports implementation. Changing the methods of oversight prior to ensuring the efficacy of the program. The paper/time burden on small operators. Concerns about adequate redress for those facing problems with the system, as whistleblowers or other. Issues that pre-date SMS and that the industry is not convinced will result in improvement post SMS.

It has been said that companies that embrace safety, already had a form of SMS in place before TC began the shift. That the companies that do not embrace safety, will only cover the truth with paper.

Comparisons have been made to similar shifts in other industries worldwide, with disastrous results. When the looking glass is removed, the infection is not spotted until it turns to gangrene.

I, for one, believe we need to take a serious look at how SMS can be implemented "safely", before it is regulated into the industry sectors that already have a somewhat more dubious record than the airlines.

Kirsten S.

[sky's the limit]

Mr Sugar,


There are a number of salient issues with the implementation of "SMS" in our industry.

First is the extreme misunderstanding of what SMS is, and how it is applied from operations the size of yours down to the single plane/helicopter charter outfit 500Km from the nearest TC office. There are unclear guidelines coming from TC, there is a lack of understanding at TC of what SMS essentially is, and most importantly there is a severe reduction in the "oversight" provided by our Regulator due to a number of factors, not the least of which is liability. This is not acceptable in an industry famous for, and built on, the competitive nature of the people in it. Self regulation is not making us safer, and without effective oversight that is where we find ourselves.

Second, SMS is something that in many cases is paid attention in training, in paperwork, and in policy, but in practice it leaves much to be desired. I've experienced it in three different companies now and have to say I'm highly unimpressed with the real-world outcomes. It may work fine in large, high profile situations like yours, Air Canada, or WestJet, I cannot comment on that, but again, in the smaller fixed wing operation or almost the entire helicopter industry, it is business as usual with the important caveat being the pilot is now ultimately responsible in terms of liability. Make a mistake and the company goes back to the form signed by the pilot or AME saying they were "trained" in that area, and they violated that training. The scope of that training is another issue as there is no standard being adhered to across the board, companies are left on their own to "develop" their SMS manuals, often importing them from other nations and industries. There is little if any guidance from TC in this area, and I am not sold at all.

Third, I see a race to mediocrity developing. Many of the older people on Avcanada, pilots in the public realm such as Capt Sullenberger, and others have been ringing this particular alarm bell for years. The problem however has never been more serious than now imho. We are not teaching pilots to think anymore, were are indoctrinating methods and standard procedure while abdicating our responsibility to inform the new generations through the acquisition of experience. Knowledge without experience is almost useless, and in my world of helicopter operations, it is leading to a serious degradation of skills and airmanship. Capt Sullenberger et al have also expressed this concern in your area of operations.

While the large jet operations have been SOP strict environments for many years, there are plenty of other applications where this is not the best method for ensuring safe operations - quite the contrary in fact. Painting bush operators and helicopters with the same brush as the 705 companies may look sophisticated and professional, but it again, it is only a facade. We are ensuring pilots are being told what not to do, but not WHY. We are training experience out of an entire generation of pilots, and I believe while SMS is not solely to blame, it is most certainly exacerbating the problem.

We have allowed insurance companies not only to dictate requirements, but also operational policy, and it is many of these policies which are wholeheartedly embraced by the Oil companies, power companies, and other large corporate entities you speak of. What's good for the goose, is not necessarily good for the gander.

TC wants no part of regulation anymore, and SMS is going to have some significant impacts in the very near future, particularly in these tougher economic times when "safety" is always one of the first departments to go. The paper may look right, the policies may read well, and the concepts may play well in the board room, but when it comes time to implement these measures in the field, they will go by the wayside with nobody there to oversee, particularly in a cash-strapped operation. This is happening already, I have seen it many times.

There are endless clever analogies and buzz words with which to package SMS, but the fact remains this concept is flawed deeply in its present form. I am 100% for a safer, more effective, and worker friendly environment, but I do not believe for one minute that SMS is the answer. We are not "other industries," we are aviation. The solutions that work well elsewhere may not always work in our various and varying environments. I think there are far too many people who who have bought in to the SMS idea without fully thinking it through. I believe the Regulatory body is remiss in its duties to the public, and I think that SMS at this point is little more than a shell lacking in substance and hiding some potentially serious problems - training to the lowest common denominator being just one of them.

Regards,

stl

[trey kule]

.......brought to you by the unoffical spokesperson and cheerleader for Transport Canada (if that is their real name)

Interestingly enough, the government hacks, in all departments get the higher ups to "agree in principle", then completely screw it up in the implementation. Its what happens when incompetent people run with a good idea.

SMS, is, in my opinion, a great thing, and has, and always will be practiced by good companies. They have just not, for the most part, bureacratstit..(my new word..not missplelled)
But TC has tried to formalize it, and in doing so, despite the cutsy cartoons in the safety bulletin, and the hype of agreement in principle, they have not done a good job. The usual cheering and selling of a good idea is no good if the product is bad, or, in this case, where the whole thing was neverly properly thought through before the big push to implement it.. After all, Canada had to be on the forefront, because , as we all know, TC regulates one of the most effective safety programs in the world. (And has the most fully developed affirmative action hiring program of any government department, I may add)

You say "point taken"..yes...and so far as I can see...point ignored. Just rush ahead and make it the operators' problems.

TC has to have an internal review and figure out how to implement it properly. Until that time, it is going to continue to be a mess and all the rationalizations that it could have been done better, but here we are , are worthless.

Who could argue with the would you rather prevent an accident rather than have one? No one. But that does not lead to the conclusion that the TC version being stuffed down our throats will prevent any either. Someday, maybe someone at TC will be able to break the mindset and actually think things through before they try and implement them.

Hope this adds a little balance and means for discussion..my rant for the day.

[PITA]

No Clearwater the best reply on this form is from Widow

The problem TC fails to understand is that you can't legislate "common sense"

[george sugar]

Trey, your point of view is not a rant but an opinion well expressed. And this is precisely what is needed on a topic of such importance, since as you point out what is meant to occur is not as important as what the perception of that occurrence is. And TC’s version is not really theirs; it is basically a QA, six-sigma type of system that has been around since the ‘80s.

One thing that needs to be dispelled is the notion that SMS equates to self-regulation; the CARs remain in force and will continue to do so. And in absence of effective company mitigation, TC Enforcement will remain a robust and active department.

SMS goes beyond the CARs. To expect that any body of legislation can envision every eventuality and possibility in advance is unreasonable. The intent of SMS is to bring formal processes to bear on situations that prescriptive regulation cannot hope to touch. Regulations by definition are enacted to codify responses to events that have already happened with a hope to prevent them happening again in future; SMS has as its goal the prevention of these undesirable outcomes in the first place. CARs and SMS are not exclusive and competitive, they are complementary.

As for the perceptions surrounding SMS, I would suggest that the concept is being paid a disservice because of the medium. If it had been ICAO, say, or IATA that had imposed this on us, rather than TC, then I suspect that the response would have been different. It is not too far of a stretch to envision that if such an outside agency had demanded we do this and TC had resisted, we would be clamouring for TC to conform to this external world-wide industry standard. Just a thought.

STL, thank you for the honorific, but Mr. Sugar is my father; please call me George. And to your point, yes; the concept of “one size fits all” is not tenable, and yes how they have gone about it has considered a very narrow view of the industry. But, in saying so, it is important that we take the good things that SMS implies to the extent that we can, rather that throwing the whole concept out because it doesn’t apply to us 100%. Also, let us forget for a moment Transport Canada and the insurance companies; why is okay that you get hurt or killed because safety is too expensive or too inconvenient and SMS doesn’t precisely fit into your segment of the industry? Your blood painting with the same brush on the conforming paper doesn’t make it right.

Including the post of Kirsten, we are all talking around the peripherals and squabbling about the “whos”, “hows” and “whats”, rather than the “whys”. We all are all advocating a better safety system, and none of us is in a position to dictate how we will achieve it. Can we not take what we have been given, and have or will be required to conform to, and maximize the benefit, instead of spending so much time and energy arguing about why it will not work?

[Widow]

George,

If I may be so bold, you have missed the point of the majority of responses so far. Everyone agrees with the concept of SMS. But to say that it is not a system of self-regulation in it's current Transport Canada form is to ignore the reality of what is happening. When SMS was first introduced to the business sector, it was called industry self-management. Nothing about the concept they were introducing has changed. Only the name.

The ICAO is mandating it in certain sectors. But they are also talking about it being "in addition to" and not "instead of". I'd be very curious to know what the ICAO thinks of the FOIP being replaced by the SUR.

Those who disagree with you here are not fighting SMS, they are fighting TC's method of implementation in the face of what some see as an already dysfunctional system.


Kirsten S.

[george sugar]

Hi Kirsten,

I am pleased to make your acquaintance, and admire what you have done. I deeply empathize with what you and your children have endured. I approach this discussion as an effort to make things better and to save others from having to suffer your loss, and hope that you will grant me that licence.

As I see it, no one is disagreeing with me at all; they are expressing their opinions about their perceptions on the topic. What may be a bit misaligned is that I am speaking of SMS, and some others are having issues with Transport Canada. While these are connected, they are not the same.

The SURs are specific to how Transport evaluates and approves the SMS of a company. IATA and ICAO only specify that the SMS be approved by the state as long as the SMS complies with their broader regulations.

I am not the final arbiter on such a discussion, but I would speculate that I am perhaps able to share since I am actively involved on a day-to-day basis in implementing SMS under Transport Canada oversight. I can only relate my experience, but what I am trying to convey is that things may not be as some believe with regard to the methods, intent, experience and insight of those that are tasked to form the front line of this exercise.

A tenet of SMS is continuous improvement, and this applies as much to TC as it does to industry. They are aware, at the ground level where things get done, that things are not perfect and that this applies also to them.

Whatever has come before, we all need to cut them some slack and allow them to work this through. The first stages of improvement always seems inadequate at first, but I truly believe that if SMS had been implemented earlier, and had become a robust and mature process, many more families would have been very likely spared the heartache you are experiencing now.

[george sugar]

To make SMS work, we have to simply accept it and make it work. That’s my point; SMS and TC are not necessarily one and the same, or prerequisites for one another. To make SMS work, those practical aviation professionals at your company with proven management/leadership skills need to understand that this is independent of what one might feel about TC. The perceived failings of TC are not the actual failings of SMS, and the success of SMS depends only on you and your colleagues. Transport does not manage it, you do. Who cares how or why we are implementing it, get beyond that and make it work for your company. It would be a shame to fail to increase safety through a proven mechanism because we have feelings about those who suggested we use it.

[sky's the limit]

Also, let us forget for a moment Transport Canada and the insurance companies; why is okay that you get hurt or killed because safety is too expensive or too inconvenient and SMS doesn’t precisely fit into your segment of the industry?

George,


It is not OK for people to get hurt or killed. In 2008 I lost four friends or acquaintances to accidents. What I am saying, and am trying to be clear about, is the direction SMS is taking us in the future. It is not simply about being better, it is about being better in a legal, liable, and traceable sense. Unfortunately the extreme lack of direction from TC is very important in this discussion and cannot be excluded, nor can the policies coming from the other parties mentioned above, such as the insurance and oil industries. These are all intimately intertwined.

I said it above, and I'll say it again - what is right for other industries in not necessarily right for aviation in a broad sense. We have a unique industry with a unique set of demands and consequences, I don't believe that the SMS models I've been exposed to are doing anything tangible to mitigate the issues we in the helicopter industry face on a daily basis. When you are flying straight and level on airways on the same routes with the same crews day after day, fine, I can see the applicability, but the Kenn Borek's and rotary companies of the industry are not dealing with this type of predictability, and you cannot train accidents out of people with proceedure. You must develop a pilot's decision making abilities and knowledge base, SMS not only misses this, it is taking us in the other direction as I eluded to above.

We sit through video after video, do test after test, and yet when we leave the classroom it is to head back out to the same old industry and the same set of demands that existed long before anyone heard of SMS. I could point you to several 20,000hr plus rotary pilots who've made a life time of some of the most difficult flying there is - accident free. How is that? More importantly, why are we not looking at those pilots to learn how to move forward instead of covering everything with endless trails of paper and videos that were produced in 1981?

I am all for a safer industry, but at this point I don't see SMS as anything other than a convenient way for the Gov't to pass the buck back to the industry, and I think that holds some very dire consequences down the road. The vernacular emanating from the SMS advocates sounds good, particularly to the public or the uninformed, but I submit to you that digging deeper will show the veneer is very thin.

stl

[flyinthebug]

clunckdriver..Now this was the post I was looking for! Your observations are quite correct.

Now, for clarity, I DO embrace the SMS itself.. and like a broken record I will state it is the implementation OF the SMS program in Canada that I am opposed to NOT SMS itself. The problem with this type of blanket implementation is that the SMALL ops are forgotten. Look at the ops with 3 float planes.. 3 pilots, 1 CP and likely 1 PRM. The "Ops Mgr"/owner will talk to his CP (and base the conversation on their "friendship") and that companies SMS will instantly become a joke.

I am not concerned about the larger companies where the "boss" cant walk down to a dock and gather his TWO pilots together, threaten them to fill in the paperwork as HE wants it. Larger companies will simply have too many employees for these types of problems to ever surface or even exist. Its the little guys im worried about.

When i showed at at my new employers last spring as his new CP.. I asked him how much of the SMS system had he begun implementing at our company?.. He looked at me like I had 3 heads and asked.. what is SMS? Meanwhile.. the large airline I had just left, had a rock solid SMS program fully implemented and running VERY smoothly. That is because they were large enough to have an SMS manager and an accountable executive and about 350 employees. SMS can and WILL work with the large airlines.. My concern is for the small ones and the ultimate safety of any op that has 2-3 lower time pilots that just want the PIC and dont much care how they get it..

If im correct.. you should start seeing an increase in small 703 accidents.. and improvement on the 704/705 level. My biggest problem with SMS is TCCA forgot about the little guy and now the same guy, has free rein to run his company without ANY oversight from TCCA. That is my ONLY problem with SMS.. Implementation! If it was implemented with hard dates and extra time given to adapt, as well as OVERSIGHT by TCCA and subsequent accountability.. Then even the 703 ops would have some one to be accounatble to. Who are these small ops accountable to? NO one! The lunatics will continue to run the asylum until this problem is addressed.

Fly safe all.

[Cat Driver]

Good morning George Sugar please allow me to make my small contribution to this discussion with the hope that you will see it as my honest opinion based on my experience in this industry.

I trust you and everyone else here will take into account my ignorance of the world of word salading using neat sounding words and sound bites designed to baffle the less intellectually gifted among us and allow me to use common words?

I will leave the nuts and bolts of the structure called SMS to the people that are still working in the industry and thus are familiar with the problems surrounding the forcing of SMS on " all " operators and just ask one question regarding your first post here.

This bit jumped out at me and got me to thinking about just how effective this will be.

Many see SMS as some sinister plot to deflect responsibility, but if anything Transport will be under even more scrutiny as we shift to this new regime;

Who exactly will be the ones to scrutinize TC with regard to SMS?

Having seen the present DGCA's totalitarian disregard for not only the people in this industry but for those who we elected to parliament who is so arrogant that a member of Parliament accused him of contempt of Parliament, are you suggesting that we should trust a system that corrupted at the top?

Thank you for taking the time to read this.

. . an SMS veteran as evident from a career of over fifty years of accident free flying.

[xsbank]

Most of the companies that have SMS have unions whereby the employees have a measure of protection, very hard-won I might add, essential to the operation of SMS. Without protection and without legal aid, SMS will not work. That is why the small companies will rarely be able to make SMS work for them as very few of them have protection for their workers.

Another call for a 'Pilot College,' methinks.

This is step one.

edited to add: TC might have a good idea but I agree totally with the previous posters that it is also the main problem. NO credibility. None, actually. I am still waiting for my new license after 4 months, and I hand-delivered it!

[Rockie]

George

SMS can be a great thing if a company embraces the concept and conducts themselves accordingly, as most reputable companies will. You know very well though that there are those that won't, and a few now defunct 705 airlines run by a couple of borderline criminals come immediately to mind. I nevertheless wholeheartedly disagree with your faith in Transport Canada.

TC pushed SMS out the door and made it mandatory for companies well before they themselves knew what it really was or had established a baseline for compliance. Someone we both know quite well was put in charge of it at TC and was still literally writing the book after the date airlines had to implement it. TC could not wait to shed the responsibility and they placed operators in the very bad situation of having to comply with something while giving no direction on how to do so.

This is all very consistent with TC's desire to get out of the whole business of doing their job. They have handed over certification for private operators lock, stock and barrell to the CBAA in what has to be the biggest con job in their history. They have left all development and compliance of standards to them placing a huge burden on an organization that wasn't set up for it and didn't want the job to begin with. They are in the process of doing the same for commercial operators, and eventually they will make themselves utterly irrelevant to our industry.

The sad truth is that dodgy operators need to be policed, and only the government can do that. The government is proving that they are no longer interested in doing that.

[SeptRepair]

Rockie has put it nicely. TC themselves are clueless when it comes to understanding exactly what SMS is. I got off the phone the other day with a friend who is a TC inspector and he said exactly that. They have no fricken clue what it is they are supposed to be doing and he sees further extensions coming to allow implementation. Further extensions? Geezus H christ. I am all for increased safety and a culture where a person can be openly and freely able to express concern without retribution. But the piss poor way Transport goes about implementing changes to the aviation industry is deplorable. They tend to forget the amount of time and energy (MONEY) it takes to blindly follow the blind. How many operators are trying to rewrite their manuals only to do it again and again and again because the inspectors themselves are learning on the fly. Transport has resources and money flowing without accountability. The industry does not. So perhaps the next time Transport Canada comes up with an idea, they should figure the goddam thing out first (even if it takes them 10 yrs behind closed doors) and then once they understand exactly what it is they are trying to do, they can come to us in the industry.

[Cat Driver]

To suggest that we can take TC's participation out of the loop when examining the effectiveness of SMS boggles the mind.

SMS properly used is not the problem in this industry, the problem is the quality of people who TC has making these decisions and stumbling along like demented drunks in the dark.

Another example of anal retentiveness in their way of doing things is the fact that they discourage anyone with experience in teaching flying from entering the flight training business.

That of course is understandable as human nature is such that when you hire the mentally slow and put them in positions of power they will naturally do everything in their power to protect their turf. Stupid then becomes the norm.

[george sugar]

I knew this was going to be a tough crowd when I walked in here. I had no illusions when I embarked on this thread that people would gasp in wonder and change their minds just because I said so; but as Kirsten knows firsthand, change does not come about when you speak only with those that agree with you.

STL, I understand what you are saying, and I also understand that many share your opinion. However, no one is suggesting that SMS should supplant pilot decision making, thorough technical training and basic skills. Those that resist SMS often imply such a notion, but it is simply not there.

In the case of a 20,000 hour accident free helicopter pilot, this person is successful under any system. What is being advocated is the creation of an environment where more people can be like that, and where such success is the result of design rather than just good fortune. SMS also puts a reporting obligation on those that are not traditionally involved in flight safety, since the issue at hand is the health and safety of all employees. The more awareness there is across a company about potential hazards, the safer everyone is, no matter how big or small the enterprise.

SMS is coming to 703 land, and it will not be easy or quick. And it will be interesting indeed through this round of validations to see what the CBAA has made of the freedoms they have been given. No doubt there have been some questionable methods displayed over the years, Rockie. And to a great extent TC has indeed acted before planning or considering the implications of those actions. But what is an alternative now; do nothing and endlessly nag about the evils and shortcomings of TC?; demand that they hire more inspectors one day then complain the next day about intrusive oversight when those self-same inspectors fine companies or take certificate action? TC recognizes the past and some very sincere and capable folks are working hard to set it right. We should not condemn their future efforts forever over the past failings of others.

It will be people like you and Kirsten, ., that subject them to such scrutiny, along with many other industry organizations and opposition politicians who will relish the opportunity to point out problems. That is as it should be.

I am not an apologist or public relations person for TC, and everyone’s opinion on this thread is valid from the perspective that it is offered. This SMS conversation needs to continue and include more people in the industry, but it needs to be a constructive exercise that moves in a positive direction rather than just being the same old complaints about the same old things. In the meantime ., consider me boggled.

[Cat Driver]

It will be people like you and Kirsten, ., that subject them to such scrutiny, along with many other industry organizations and opposition politicians who will relish the opportunity to point out problems. That is as it should be.

Yes, unfortunately very few actually step forward and put their careers and livelihood on the line because they are guaranteed to lose.

I knew that would be the result when I decided to expose the rot at the top of TCCA and can prove it with documentation in the form of letters to the top managers in TC wherein I told them that even knowing they would destroy my business and try and end my career I was going to do it anyhow.

Few step forward because they know they will be punished severely for doing so.

I am very happy with what I did because I can now show proof that at the top they are morally corrupt and tyrants with the power to destroy whomever they wish.

I am not an apologist or public relations person for TC, and everyone’s opinion on this thread is valid from the perspective that it is offered. This SMS conversation needs to continue and include more people in the industry, but it needs to be a constructive exercise that moves in a positive direction rather than just being the same old complaints about the same old things. In the meantime ., consider me boggled.

O.K. I'll consider you boggled George Sugar, but in the final analysis you are just anothr stranger to me in cyberspace who had an agenda and is putting it forward. I don't mind expressing my own thoughts and do so openly.

['79K20driver]

'george sugar' is infact the same George Sugar that is the VP of flight ops at Cargojet. He's not hiding that. Naturally, Cargojet's a 705 company. George's opinions on SMS will therefore be bent, but perhaps justifiably.

I do agree that SMS can work especially in the 705 world where many companies have previously had their own SMS type system in place. I think TC is bringing it to the rest of the industry too quickly. Some 704 companies will integrate it without much trouble but many will struggle. For 703, I don't think it works at all. It comes down to a question of manpower and separation from ownership. Larger companies can create safety committees and have SMS reps to monitor it while the shareholders view it as just one of the costs of doing business. On the flip side, many (but not all) of the smaller companies barely have enough time to run the Revenue Canada and Canada Labour Code side of things, let alone run a TC SMS program. Who's going to oversee it in an honest fashion at these companies? The Owner? I doubt it.

[bezerker]

I want to respond to the opening post. It is a well written post but unfortunately in my opinion there are many assumptions made that are simply not true, or at least worthy of argument.

Would you rather have an accident, or prevent the accident altogether? If it is the latter, then you should be an advocate for SMS. Any objections to SMS then become not a matter of foundational principles, but rather questions of personalities, methodologies and any other axes in the tool shed we care to grind. If we can get consensus on this basic premise, then we are most of the way to being safer as an industry.

This implies that there is only two sides to safety. You are either for SMS and reduced accidents or against it and therefore are inherently unsafe. So now we are either good or evil, for safety or against it. This is simply not the case and is obviously shown by the many individuals and companies that have been accident free for many years without ever hearing about SMS. There is no question that those who embrace SMS (especially those that have chosen to do so before it being mandated) have a great framework for increasing safety. But there are other ways to impose safety on those that aren't, i.e. regulations and enforcement.

For whatever reason, Transport Canada chose to be in the forefront of requiring SMS. The people that made that choice had a particular vision for how it should be implemented, and arguably this vision should have more thoroughly developed, communicated and planned than it has been. Point conceded. However, the foundational principles remain valid no matter why we think Transport did it, whose idea it was, nor what transpired during our dealings with Transport in the past. And as the concept has had time to mature, SMS is evolving and now being rolled out in a very orderly and effective fashion, and is accruing real value to those companies that have put it in place.

That is a great paragraph. To summarize:
1. SMS is great for those that have chosen to put it in place,
2. TC had nothing to do with inventing this good idea,
3. TC has decided that because this is good for some, it must be good for all, and
4. TC has royally screwed up the implimentation of it.
I would argue that it is not being rolled out in an "orderly and effective fashion". One only has to look at TC's implementation webpage under 702/703/704 http://www.tc.gc.ca/CivilAviation/SMS/i ... tation.htm
to see how unorganized this still is.

The basic idea of SMS is that we as individuals and companies are responsible for our own safety. Through proven methodologies customized to our particular circumstances, we are given documented and formal processes to see where we are, where we want to be, and the means to measure how well we are approaching and maintaining those goals. To the many who have complained about intrusive oversight, one would think that this would be just what we have wanted; so why all the resistance?

Here you are assuming that all companies want to change how they presently deal with safety. You also neglect to mention those companies that are requesting more oversight. Most of use that have been around the block know which companies have an unsafe culture and many would choose more oversight be given to them. Obviously companies that choose to bend or not follow the rules are going to be the ones demanding less oversight and promoting self regulation. Does anyone see a problem with that?

SMS does not mean that Transport oversight will simply go away. Rather that oversight will now measure how well we perform under these increased responsibilities we have asked for all these years. Many see SMS as some sinister plot to deflect responsibility, but if anything Transport will be under even more scrutiny as we shift to this new regime; everyone is suspicious of change, even if it is for the better, but is that a valid excuse for not improving?

If TC can't comply with their oversight mandate now (as told to me by multiple CAI's and observed by the reduction in audits over the past few years) why would we expect them to be able to oversee SMS once in force? Also you again imply here that SMS is an improvement for all, which is an assumption.

They will not hand over the keys so easily though. Until a company demonstrates that they are willing and able to accept this responsibility, they will not be certified. The implications of this are that some operators will not be permitted to continue to operate. This will be the sharp point for the employees that currently complain about unsafe conditions; you may be forced to seek other employment because the operator you work for, and have complained about, will have its certificate pulled. Gone will be the pressure to press on regardless in an unserviceable airplane in marginal weather, but perhaps this will be replaced by other more personal pressures.

Unsafe rule benders have always been able to obtain an AOC and maintain it. It is hard to believe that there will be any change in this. This is one of the fundamental flaws in mandating SMS, you can't force an owner/company to have a safe mindset. Either they do or they don't. People will be able to BS their way through the SMS paperwork and implimentation whether or not they embrace it, in exactly the same way they have gotten through audits of the past.

You also mention here that when you fill out an SMS report, it may cause your employer to close its doors. This is a massive flaw in the system. Many pilots in this country that don't work for an airline are of two types. One is the guy who needs his current job for experience (whether it is f/o on a Navajo or captain on a Learjet) (and he may have waited jobless for months/years to get the position) and the other is the guy rooted in his community (wife with job, house, kids in school, etc.)(and maybe in a "one aviation company town"). In both cases there is no incentive (and in fact very harsh life penalties) for whistleblowing. So, the "the pressure to press on regardless in an unserviceable airplane in marginal weather" will be there as always.

Whistleblower protection is another huge factor. Who gets upgraded, the guy who flies without complaining, or the guy who fills out forms that cost the company thousands of dollars? It will be the same as it always was, keep your mouth shut or pay the price.

SMS as an idea is not new; it has been standard practice among large multi-national industries for decades. Quality control and quality assurance are widespread business concepts, and indeed aircraft maintenance organizations have operated to these standards for some time. SMS is also an idea whose time has come to aviation whether we like it or not; IATA requires an approved SMS as a condition of membership, and the FAA is well on its way to requiring it in more or less the Transport Canada form as well.

Mandatory SMS is an oxymoron. Pretty soon every operator will have an SMS binder in the office somewhere, with or without TC, not because it is regulated but because of contract and insurance requirements. Many large companies already require an SMS in order to work for them. As already stated, having it and meeting the requirements of it does absolutely nothing for safety. For many companies it will be just another binder on the shelf next to employee forklift training, dusted off to show auditors once every few years.

In Canada, given our broad spectrum of aviation activities, we have to ask if safety is a consistent concern across all facets of aviation. Is not someone who pays to fly on an Otter to Tofino entitled to the same level of safety as an Air Canada passenger to Osaka? Is one life any less valuable than another, and is one life any more valuable if it is put at risk in the company of hundreds rather than just 18?

Are you saying that a VFR Otter on floats flying the BC coast will have the same accident/fatality rate as an A320 because of SMS? As STL pointed out, 703 is not the same as 705.

SMS is here, and it is a reality of the present day and the future in our industry. Just as us stick-and-rudder old-timers need to get over the evils of automation and glass cockpits, we also need to accept that this is the way our industry is going. Just as the flight deck has turned into an exercise more in management and strategy rather than tactics, the safety culture of airlines is becoming more forward-thinking and predictive, rather than reactive and regretful for the things we should have done to prevent an accident. To resist such a change seems irrational, and we need to get over the nit-picking and lend our expertise and experience to the opportunity that Transport Canada has thrust upon us.

It is interesting that you use the term "airlines". There are no "evils of automation and glass cockpits" when flying a clapped out Navajo in the middle of the night to some black hole approach.

I don't want this to seem like a post about Bezerker vs. George Sugar. It is just that you have covered a lot of points to do with SMS and I have strong opinions of SMS and small operators. The bottom line is that I don't see how it is possible to "force" safety on someone. If it isn't possible, then why waste countless resources developing, implementing, maintaining and training for it.

Cheers.

[flyinthebug]

'george sugar' is infact the same George Sugar that is the VP of flight ops at Cargojet. He's not hiding that. Naturally, Cargojet's a 705 company. George's opinions on SMS will therefore be bent, but perhaps justifiably.

I do agree that SMS can work especially in the 705 world where many companies have previously had their own SMS type system in place. I think TC is bringing it to the rest of the industry too quickly. Some 704 companies will integrate it without much trouble but many will struggle. For 703, I don't think it works at all. It comes down to a question of manpower and separation from ownership. Larger companies can create safety committees and have SMS reps to monitor it while the shareholders view it as just one of the costs of doing business. On the flip side, many (but not all) of the smaller companies barely have enough time to run the Revenue Canada and Canada Labour Code side of things, let alone run a TC SMS program. Who's going to oversee it in an honest fashion at these companies? The Owner? I doubt it.

Well said!, (espically the part in bold and wherein lays my deepest concerns)

Its not the Kenn Boreks im worried about.. Its the mom and pop 2-3 plane ops with low time pilots, only seeing hours and not caring about this level of "safety"..

I agree it cannot EVER work on a 703 level WITHOUT oversight!

Fly safe all. Cheers

PS.. Great post berzerker!

[george sugar]

Bezerker, I appreciate your thoughtful analysis and response, and it is not at all perceived in an adversarial way. This whole thing is a discussion, not an argument.

I was not as clear as I should have been with “This will be the sharp point for the employees that currently complain about unsafe conditions; you may be forced to seek other employment because the operator you work for, and have complained about, will have its certificate pulled.” When I said “complained about”, I should have added prior to SMS. It is very unlikely that an SMS report would get an OC pulled or a person violated as long as the company’s process is followed. The certificate pulling I referred to was in reference to those that fail to become SMS compliant when required to do so. Apologies.

If I may, I might point out a seeming contradiction in your analysis. Early on you say that regulation and enforcement are methods of imposing safety, but then in the concluding paragraph you say that you do not see how it is possible for force safety on someone. Which ever way it was intended, the problem with enforcement is that it usually only kicks in once someone has been exposed to a hazard. I fully agree with you, though; someone who willfully breaks regulations is unlikely to comply with the intent of SMS anyway, but that is not to say that we should just shrug it off and allow non-compliance of any form to continue.

Keep up your efforts. See SMS for what it is, and what it is not, in your particular circumstance, and continue to share your views with those around you. The point of SMS is safety, not a nice shiny binder on the shelf and a meeting once a month, and if you can bring even one new initiative to your operation as a result of the SMS debate, then it has been of value.

[bezerker]

Hi George. I agree that this is a good discussion.

I think I can answer my seeming contradiction. I don't believe you can enforce a mindset, only rules. However I believe that a level of safety can be maintained with rules/enforcement, even though (as you mentioned) enforcement is generally imposed after the fact.

An example may be Canadian drivers. Are we generally safe because of the rules imposed on us and by the monitoring and enforcement of these rules by the nations police? I somewhat think so, although there is probably room for improvement (lots of room in some cities).

I think about what life would be like if we implemented SMS on the highways and roads of this country. No more cops patrolling the road, as individual drivers would regulate themselves, reporting their infractions in a book at home, coming up with ideas on how to improve their driving abilities, all to be audited every once in a while. I believe that some drivers would better themselves through this "Highway SMS", but I'm pretty sure that within a few weeks the roads would look like something out of Mad Max. Those that broke the traffic regulations and drove unsafely before implementation would be in their glory with self regulation.

My example given is not the greatest, but the key point is that "Highway SMS", although a good idea, will not make our roads safer simply because of those that choose not to embrace it. The current method which relies on the fear of getting a ticket/fine or losing our licence works to keep most drivers in line, thereby providing us with safe roads to travel on.

I think everyone agrees that SMS will increase safety at any company that embraces it. But just like my wife's cat that craps on the floor when I am not paying attention, some people will always need both someone watching, and at times a good spanking if caught after the fact to keep them from repeating the same offense too often.

Cheers.

[george sugar]

I guess that’s what you get for allowing a cat into your home; there’s an easy solution for that which does not involve paperwork and meetings!

The driver analogy sort of fits, but differs on a few essential points; among others, the level of certification required in obtaining and retaining a driver’s licence or car is minimal, and drivers in general do not take money from the travelling public and provide a service. More importantly, one would hope that the ranks of aviation personnel are populated by more capable and thoughtful persons than the average driver.

If we have aspirations to be taken more seriously as an industry then we need to move further away from a mind-set of getting away with stuff unless there is someone looking over our shoulders, both on a personal and corporate level. As it is now with a prescriptive regulatory regime in place, TC cannot possibly monitor every departure or maintenance procedure and we are already essentially left on our own to do the right thing. Sadly, people regularly ignore the rules and common sense, but a professional approach to this is not a bigger stick to keep them in line. In one respect, the present system is in itself not sustainable since every time someone does something goofy, we get new regulations and training courses, and we are very near the point of non-functionality due to the mountain of prescriptive measures already in place.

Earlier on, in objecting to SMS, xsbank brought up the “pilot college” as an alternative, but what is a pilot college or industry-wide pilot association if not an SMS/self-regulation concept in itself? Such a body would be doing the same things on an inter-company basis that SMS is trying to achieve at the intra-company level, and the members would be held to the same higher standard. When thinking of the problems of SMS, it may be informative to ask oneself how non-compliance and transgression would be handled by the college, and then bring that to SMS.

The SMS discussion has been de-railed a bit by becoming an argument about personalities and people rather than concepts and ideas. Folks seem to have developed a visceral mistrust of the whole thing and convinced themselves it will not work, and I fear that this will become a self-fulfilling prophecy. My purpose here is to ask that we question our premises, and maximize the value in something that is clearly here to stay. Because the point of the whole thing is the safety of ourselves and our customers, and it is a pyrrhic victory if we prove it does not work by hurting more people.