SMS

[snaproll20]

I think STL is correct.
The major problem has always been TC's reluctance to shut down the 'bad apples'.
It is grossly unfair and should not be acceptable that friends of mine who run good operations shut down because the financial burden is too great.
SMS ( itS a MesS) is a disaster for small operators.
I am just glad, like many other older folk, that I do not have to concern myself with it.

[Rockie]

Prairie Chicken

You aren't thinking in a devious enough way to see how this SMS system can be abused by a shady operator. Yes, if an operator takes safety to heart and truly regards it as their responsibility then why is Transport Canada even required? But there are many operators out there who view SMS as an opportunity to do whatever they like as long as they have the proper paperwork to show to anybody from the government. In the private operator world it is the operators themselves who decide what the standard is. It is then up to them to hire a contract auditor to do a paper audit only for submission to the CBAA (which used to be strictly a operator advocacy organization) to continue operating. The key thing here is that the auditor works for the company that hired them, not an arms length organization. What are the chances that a failing grade on an audit will result in a repeated request to conduct another for the same company?

SMS is completely incestuous, and is open to unfettered abuse by people who only want to make the most money in the easiest possible way in this industry. And this industry is full of people like that.

Transport Canada's primary function in my opinion is to ensure the safety of the travelling public. With SMS and now the fatigue management counter-measures initiative they have started they have completely reneged on their responsibility. They are leaving the public (and airline employees) completely at the mercy of the shysters in our industry. Their common refrain is that SMS provides an additional level of safety in the transportation industry. And that would be true if Transport Canada still did their part. But they aren't, which means SMS is the only level of safety, and it is only as good as the operator wants it to be.

In other words, it is only a matter of time before airplanes start impacting the ground because Transport Canada has decided to not do their f*****g job anymore.

[synthpro]

SMS is a joke.

Its like handing out instructions and a training program to make sure you look both ways before crossing the street.

[Hedley]

Inquiring minds want to know ...

About these "bad apples" I hear so much about ... I
presume that Bob Hoover must have been one of
these "bad apples"?

[Chuck Ellsworth]

TC is very selective in determining who they deem to be a " Bad apple. " for some reason I was put in that category and not only did they refuse to issue me an OC they prevented me from even using my license pilots license to work in Canada.

Mind you being forced to leave Canada was the best thing that ever happened to me as a pilot.

Anyone know where Merlin Preuss went?

[Prairie Chicken]

Stl, I guess we first need to determine whether we are in agreement that the philosophy of SMS is good and TC’s implementation is bad &/or naive. If we can agee on those two points, it will safe me a bunch of typing.

The focus of this forum seems to be so negative! I fully believe there are many good small operators out there that have been applying the principals of SMS for years. They may need to take some time now to put their simple processes into a small manual, and record at least a few of those nightly over-the-dinner-table meetings they hold. They’re good operators, and it isn’t that difficult to document their processes.

But yes, I fully agree TC & SMS have created a great opportunity for the bad apples to falsify, lie, cheat, and generally operate with far greater freedom than ever before! Your concern the unsafe operators will survive while the good & honest ones fail is a valid one. In this regard I do hope the private auditors will do what TC has elected not to do.

As far as the private auditors are concerned, the first question is, what are they auditing to? What protocol? Other threads have raised the idea of a College of Professional Pilots. If such a college were to identify the standards to which operators are audited to, would that be satisfactory? I suggest standards set by the such a College & audits conducted against such standards would be a worthwhile endeavour.

As far as capitalism & greed are concerned ... I don’t disagree with you at all. Our neighbours south of 49 trusted the market to operate conscientiously, and we know where that got us! We have the CARS, and a regulator that IMHO should be enforcing those regulations until the inspectors in the hangars & cockpits are fully satisfied the company has embraced a culture of safety and are continuing to operate in a safe manner. And then they should continue to watch. Trust, but verify!

Rockie suggests I’m not thinking in a devious enough way. You’re right, I’m thinking positively, but I have seen firsthand operators hiding behind SMS and I didn’t like it one bit! I am not so naive as to believe those operators are not out there. I further agree that in the perfect world TC Enforcement wouldn’t be necessary. Unfortunately, this isn’t a perfect world.

Rockie says

The key thing here is that the auditor works for the company that hired them, not an arms length organization. Let’s Identify who is hiring the auditor. I strongly suspect it will be either the customer, or an auditor acceptable to the customer.

Rockie goes on to say

Transport Canada's primary function in my opinion is to ensure the safety of the travelling public. With SMS and now the fatigue management counter-measures initiative they have started they have completely reneged on their responsibility. They are leaving the public (and airline employees) completely at the mercy of the shysters in our industry. Their common refrain is that SMS provides an additional level of safety in the transportation industry. And that would be true if Transport Canada still did their part. But they aren't, which means SMS is the only level of safety, and it is only as good as the operator wants it to be.

I agree.

[SeptRepair]

The focus of this forum seems to be so negative! I fully believe there are many good small operators out there that have been applying the principals of SMS for years. They may need to take some time now to put their simple processes into a small manual, and record at least a few of those nightly over-the-dinner-table meetings they hold. They’re good operators, and it isn’t that difficult to document their processes.

Have you ever owned your own business and had to try and make a living in aviation in Canada?

[Chuck Ellsworth]

Have you ever owned your own business and had to try and make a living in aviation in Canada?

Very good question, I sure have and would never ever consider owning another one only because of the mind numbing reams of paper work that must be done or you will for sure lose your business...however I have to admit it is getting safer as more and more small businesses close their doors because the overhead trying to comply with all the paper work is just to time consuming and costly.

I somehow managed to maintain a perfect safety record for over fifty years in aviation without having to spend my time convincing some drone sitting in a TC cubicle that I was operating safely.

Win lose or draw all you TC types out there you can't argue against facts such as that.

[Prairie Chicken]

No SeptRepair, I have not. I had a very close friend who did, and I watched him struggle & ultimately lose the business. And I have been closely involved in an ISO non-aviation operation. Not the same though, I know.

., I'm glad for you. That was a different time though, and things do change--usually for the better, but not always.

[Chuck Ellsworth]

., I'm glad for you. That was a different time though, and things do change--usually for the better, but not always.

What we have here is an unsolvable problem due to the vast chasm between the regulated and the regulator.

The regulated is forced to comply with non productive eye candy for the regulator in the form of paper work that can be used to by unscroupilous operators as a license to continue to operate outside of the rules.

It is unsolvable because of the disparity between the regulated and the regulator in that regardless of how stupid a rule may be coming from the regulator the regulator will prevail because they have the power to enforce anything they wish to and they do not risk losing their business because they have no idea what a business really is.

The answer therefore is either provide the paper work or be forced out of business.

The end result will be a farce that will eventually end up in disaster.

Not to mention an adversarial relationship between the regulator and the regulated and a dilution of real compliance.

[snaproll20]

Some good observations there, ..

There certainly is a gap between the Industry and the regulator.
This gap has been generated by previous Director General's of Civil Aviation. The disregard for the 703,704 sector especially has amounted to sheer contempt. (They do not even listen to their own staff, so how could Industry have a chance!)It has not helped to witness open deceit, lies, and protection of unsavoury characters they have hired, but refuse to fire. Not only has the moral stance of these people in Ottawa been deplorable, they have continually violated the Civil Service Code and should have been fired. It must be a tough place to work for Inspectors who have values.

Transport Canada Civil Aviation has not lived up to its obligations under the Air Act and continuously hoodwinked the Canadian public into believing they "never fail to act."

The result is that so many of us have been soured to the point we are glad to be out of aviation. The new inspection processes are a creeping initiative to have unqualified drones with clipboards going around and shutting down operators who have not complied in some minor way with paperwork. The whole paperwork issue is entirely subjective and a continuing procession of TC personnel through any company will contradict, "recommend" and countermand wording in a document in a mad whirl of madness where the lunatics are running the asylum. This whole process has nothing to do with safety.

So far, I have seen no "welcome to my world" communication from the new DG. This causes me to fear for the worst.
It would be a great thing if he copied the initiatives, practicality, enthusiasm and communicating skills of his opposite number at the FAA.

Where are you, Martin?

Widow's initiatives have done more than the whole Ottawa clan to raise safety awareness, but I still believe that steering committees would go a long way towards reducing friction, providing two-way understanding, and terminating future dumb initiatives that Ottawa comes up with. These committees, as previously suggested, would be made up of retirees from all aviation sectors who could apply some wisdom to issues. Maybe then, and only then, TCCA may get some respect.

Now, where is that goddamned lazy bastard Jose with my tequila?

[Chuck Ellsworth]

Where are you, Martin?

Snaproll we know TCCA reads our posts, especially mine.

If Martin is a principled decent human being who truly wants to do his job I can help him get the backing of industry very simply.

All he needs do is read my file regarding the unlawful bankrupting of my company by Merlin Preuss and Dave Nowzek.

Here it is Martin:

TC file #5051-12391

Therein he will find that the DGCA agreed that if my allegations regarding wrongdoing by Preuss and Nowzek were proven to be true he would fire both Preuss and Nowzek and as well reimburse me $250,000.00 for my losses.


The findings were that both Preuss and Nowzek were guilty of wrongdoing.

So here is a deal Martin, you step forward and read the file, if you have any doubts as to the truthfulness of my statements above I have witnesses to the deal made between me and the Director General.

Pruess is gone but you can fire Nowzek.

You do that and I will drop my claim for the $250,000.00 your department owes me.


To me integrity and morals far outweigh money.

. ..

AA38841

If you refuse to do your best on this then in my mind you are just another self serving unprincipled corrupt disgrace to the office you hold.

[flyinthebug]

This is a good debate...

Id just like to offer an example of how SMS on the 703/704 level can affect safety in a negative way, Maybe if its laid out with an example, those that are firmly behind SMS (and its implemetation) may take a 2nd look. When widow appeared on the Rutherford show.. the guy seemed to think some of us "air safety advocates" were nuts? He asked HOW or WHY would an airline purposely do something illegal that would affect safety? Here is just a short i.e of what we are suggesting is occuring.

Lets say I taxi up to the hanger in a PA31 and start to tell the DOM or one of the engineers what the aircraft was doing and what I felt was wrong. After they pull it in, they determine the turbocharger is pooched. Ok.. this is where SMS fails us in the 703 sector of Canadian aviation. The turbocharger is removed and sent out for rebuild. Only, its not sent to an authorized AMO. Its sent to Joes diesel repair and rebuilt for about 35% of the cost of getting an accredited and approved rebuilder. Is this safe? See, even before SMS, small ops were trying to get away with this type of UNsafe practice and even believed Joes diesel shop did an equally good job with the rebuild, when infact, its not even close..The standards to which "joes diesel shop" and an approved rebuild facility for PA31-350 turbo rebuilds is vast.. as far as level of quality. This is only an example of one way SMS on 703 fails us all.

Under the new SMS, this will become a much easier task for the "shady ops" and once again undercut the honest op that paid the extra 65% to have their supercharger rebuilt to spec. Hence, the shady op can offer cheaper prices with less overhead.


To me, that is just one example of how SMS is flawed.
Something to think about at least.
Fly safe all.

[Prairie Chicken]

fly, I see your point & have my doubts TC would pick up the flaws in an instance such as you describe. At this time anyhow. However, ISO auditors will typically look for proof of ISO or equivalent accreditation for all companies that service an ISO enterprise being audited. The intent is to prevent exactly the type of situation you describe.

I don't think aviation is there yet though.

[flyinthebug]

PC.. with all due respect my friend.. Its already happening. Ive spent 15 years in the bush and you would be surprised how this and many other similiar issues arise and occur.
SMS on this level has only made the paper trail that much easier to fudge. Sadly, in a FEW select ops, this type of thing does occur. If I hadnt seen it, I wouldnt be saying it. The good still far outweigh the bad, but sadly its becoming a less wide gap.

Fly safe all.

[lost in the north]

looking for help,anyone have sms done foe a small mom and pop vfr 703 operation,wanting sor ideas for my own.

[HS-748 2A]

It's not officially a requirement yet. You are just trying to get a head start?

The PMIs in my region have been telling small operators to hold off because they don't know what the template is going to look like.

'48

[paydaymayday]

There's a cartoon in the Aviation Safety Letter that will help you through it. It looks like it is your situation exactly, in fact. They seem to enjoy it so much, and everything always works out. Clearly this SMS thing is a good idea and will work well in every implementation.

[Widow]

lost in the north, I've merged an older thread that had some information ... Note that SMS for 703/704 is due to hit the NPAs in December, and in regs by Feb.

paydaymayday - do you mean this cartoon?

[Rubberbiscuit]

This is a good debate...

Id just like to offer an example of how SMS on the 703/704 level can affect safety in a negative way, Maybe if its laid out with an example, those that are firmly behind SMS (and its implemetation) may take a 2nd look. When widow appeared on the Rutherford show.. the guy seemed to think some of us "air safety advocates" were nuts? He asked HOW or WHY would an airline purposely do something illegal that would affect safety? Here is just a short i.e of what we are suggesting is occuring.

Lets say I taxi up to the hanger in a PA31 and start to tell the DOM or one of the engineers what the aircraft was doing and what I felt was wrong. After they pull it in, they determine the turbocharger is pooched. Ok.. this is where SMS fails us in the 703 sector of Canadian aviation. The turbocharger is removed and sent out for rebuild. Only, its not sent to an authorized AMO. Its sent to Joes diesel repair and rebuilt for about 35% of the cost of getting an accredited and approved rebuilder. Is this safe? See, even before SMS, small ops were trying to get away with this type of UNsafe practice and even believed Joes diesel shop did an equally good job with the rebuild, when infact, its not even close..The standards to which "joes diesel shop" and an approved rebuild facility for PA31-350 turbo rebuilds is vast.. as far as level of quality. This is only an example of one way SMS on 703 fails us all.

Under the new SMS, this will become a much easier task for the "shady ops" and once again undercut the honest op that paid the extra 65% to have their supercharger rebuilt to spec. Hence, the shady op can offer cheaper prices with less overhead.


To me, that is just one example of how SMS is flawed.
Something to think about at least.
Fly safe all.

First of all I will say that although SMS seem to be working very well in our operation (705), I am on the fence about how and if it will work for the smaller operators. I have no doubt it will work in bigger 704 ops that do scheduled flying. In the example above no SMS or CARs will serve to prevent it in my opinion.

What I like about SMS is that it puts more control in the hands of the employees. If the pilots, maintenance or ground crew see something as a potential safety problem and start filling out reports the company is forced to act and cannot choose to ignore it. Can this work for the small operators? Depends on if the employees have any balls I suppose. If pilots complain about a fuel tank at an remote airport not having a proper grounding the boss would have to address the issue if one ore more SMS report comes his way.

I do not think SMS will make it any easier or harder for shady operators to hide from TC. The ones that were good at it under the old system will probably outsmart SMS as well. The problem though for these operators will be that under the old system they went under the radar by hiding deficiency's and NOT documenting maintenance issues, incidents etc. Well, lack of documentation or failing to document incidents and hazards will raise red flags under SMS and get you in trouble. When TC shows up now they know you are lying if you claim to have had nothing worth an SMS report happen since last time they stopped in, whether you are 703, 704 or 705.

As far as it being a huge financial burden I have difficulty seeing how. You need some forms, someone to review and categorize the forms as they come in,an SMS manager, an accountable executive, and a plan for following up on the reports that require some kind of action to be taken. These positions can and is usually filled by pilots etc ( with exception of accountable executive which is usually someone in management) that are already working for the employer and know the day to day operations.

My 2 cents.

[Widow]

Rubber Biscuit - glad to hear SMS is working at your outfit. Has your employer adopted a method to "guarantee" that reporters will not face any reprisal? I ask, because it seems that something of this nature has been a problem at some outfits. According to Dan Adamus, there has been "unwarranted discipline to pilots due to improper interpretation of the Safety Management System". (http://www.alpa.org/portals/alpa/pressr ... 0-1-09.htm)

[Rubberbiscuit]

Yes we have a "Non punitive reporting policy" which is brought to your attention during SMS training and Crew Resource Management training when hired on. This policy does not protect anyone who chooses to willfully or purposely break regulations or put crew, pax or aircraft in danger.

I would like to add that I do believe proper Government oversight of aviation is necessary with or without SMS.

[Dust Devil]

In my opinion SMS is fine as long as the company and accountable executive are on board with it and the spirit of SMS. If you are contemplating implementing an SMS ahead of time I think that is commendable. I'm currently working on ours. My first step was taking a course in it. The company provided a lot of good examples of how to effectively implement it.

I don't think however that SMS should replace TC oversight. That does appear to be what is happening. I think a better way would be requiring companies to have a SMS program in addition to TC oversight.

TC oversight in my mind is the key issue however I see SMS being used as a term used for deregulation and it doesn't have to be that way. How can a system used for managing safety be a bad thing. The bad thing is not ensuring that the system is being used properly. That comes with the oversight of TC.

[Dust Devil]

First of all I will say that although SMS seem to be working very well in our operation (705), I am on the fence about how and if it will work for the smaller operators. I have no doubt it will work in bigger 704 ops that do scheduled flying. In the example above no SMS or CARs will serve to prevent it in my opinion.

What I like about SMS is that it puts more control in the hands of the employees. If the pilots, maintenance or ground crew see something as a potential safety problem and start filling out reports the company is forced to act and cannot choose to ignore it. Can this work for the small operators? Depends on if the employees have any balls I suppose. If pilots complain about a fuel tank at an remote airport not having a proper grounding the boss would have to address the issue if one ore more SMS report comes his way.

I do not think SMS will make it any easier or harder for shady operators to hide from TC. The ones that were good at it under the old system will probably outsmart SMS as well. The problem though for these operators will be that under the old system they went under the radar by hiding deficiency's and NOT documenting maintenance issues, incidents etc. Well, lack of documentation or failing to document incidents and hazards will raise red flags under SMS and get you in trouble. When TC shows up now they know you are lying if you claim to have had nothing worth an SMS report happen since last time they stopped in, whether you are 703, 704 or 705.

As far as it being a huge financial burden I have difficulty seeing how. You need some forms, someone to review and categorize the forms as they come in,an SMS manager, an accountable executive, and a plan for following up on the reports that require some kind of action to be taken. These positions can and is usually filled by pilots etc ( with exception of accountable executive which is usually someone in management) that are already working for the employer and know the day to day operations.

My 2 cents.

I agree 100%. SMS is not a major cost issue. They key to it being successful is to have everyone on board with it. It will take time possibly a decade to get the old system out of peoples blood. But it will happen.

[bezerker]

I love Blackfly air!