SMS From Another Perspective

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Re: SMS From Another Perspective

Post by xsbank »

I meant that SMS is only working for companies that are large enough to deal with the further burden of paper, but primarily it will only work in companies where there is protection from persecution for pilots. Unprotected pilots, nobody will buy in. That's where the '"college" suggestion comes in, to protect all pilots under an umbrella in companies where they are too small or it is too impractical for a union.

I had experience with a company that struggled to form a union because of capricious management treatment of pilots based on your ability to brown-nose vs your ability to earn revenue and during that time there were too many accidents. Now, with the union, there was finally a body in place to act for the pilots in their defense if there were infractions, including legal protection from the union legal team.

The first step in the turn-around was the company adopting SOPs and yes, checklists - that alone dropped the accident rate dramatically. Finally the insurance company said 'enough.' The company's response was to adopt a primitive SMS and hire a safety officer, hold 'safety meetings' (formal ones, not the bar kind). Now, accidents are rare (I won't say non-existent because, well, you know).

The key to all this was pilot protection. Whistleblowing is now part of the culture and debriefings are part of every mission.

In summary: pilot protection, then a large enough company to absorb the bureaucratic BS, the need to change an unsafe culture, then SMS. In that order.

Simultaneously a sea-change at Transport, which is seen as a total gong show. That perception must change with the ordinary pilot and company before SMS (or similar) will ever be fully adopted.

Did you know a full-time aviation inspector still only gets paid about $90,000? No wonder there is little attraction for talented people, unless in a recession.
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Re: SMS From Another Perspective

Post by xsbank »

Transport seems to just want to be only a bureaucracy, with fixed buildings and a fixed, relatively low-skilled workforce where nobody goes out of the buildings except perhaps to trade shows, they can abandon their old ratty aircraft and all the mechanics and techs, just hire ex-pilots without medicals and redirect their budgets into increasing the (cheap) workforce.

The bigger the workforce, the more perks the managers make, the more managers there will be required and the whole bloated bullsh*t turns into a gun registry, lots of cost for little measurable benefit.

In short, the Canadian way.

Just look at Indian Affairs, or Native Welfare, Revenue Canada which feeds itself before it feeds the programs, Federal Fisheries that wouldn't recognize a fish - wipe 'em out they are too annoying; the food regulation agency that doesn't regulate food. Gigantic bureaucracies that produce little measurable affect for their budgets. How about the ombudsman who isn't allowed to Ombud, the auditor who nobody takes seriously, CSIS who do whatever they want, the RCMP who seems to hate the populace...I should stop.

When these agencies were set up, they were lean and they worked. Now, it is like a green patch in a pool, it grows and feeds off itself until it becomes a problem and it requires a huge dose of corrective chemicals to sort out.

Transport needs a dose of chemicals and someone to clean house. Give all those old bozos like Preuss (rip) a golden handshake and set up something that works for Canadians, not just sends out mindless news releases about how lucky we all are.

All of this is tied to a successful SMS program. I just do not see either the prerequisites or the culture to successfully adopt this program, yet. All I see is another Canadian bureaucratic farce that feeds off my taxes and is trying to shirk its responsibilities.

I do not think I'm alone.
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Re: SMS From Another Perspective

Post by Cat Driver »

Transport needs a dose of chemicals and someone to clean house. Give all those old bozos like Preuss (rip) a golden handshake
You are advocating giving someone who has a history of ignoring the very laws he was hired to uphold a reward?

Where do we draw the line, should we reward all the convicts in jail by forgetting what they did and give them a golden handshake?

God Damn it I wish I had it all to live over because I would have done things differently, and for sure I would have had the same contempt for the rules as Preuss has, that way I would have gotten my golden handshake.

All I have now is some documents that say I was to be paid $250,000.00 for what Preuss allowed to happen to me.

Should just find him some dark night and collect my money from him in person?
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Re: SMS From Another Perspective

Post by xsbank »

Probably not, Cat! We would have to get Widow to bake you a cake with a file in it.

I couldn't just say shoot the bastards, could I?
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Re: SMS From Another Perspective

Post by Shiny Side Up »

Given how criminal law works in Canada Cat, you'd probably be out in no time anyhoo. But then again we could also dredge up all these posts on AvCanada to put together a pretty convincing insanity plea. :wink:
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Re: SMS From Another Perspective

Post by snoopy »

With all due respect George, I wasn't going to respond to the original post which had the feel of bafflegab and politispeak, but I suffer from lack of restraint which now consumes me. I shall put my closing points first in case the reader tires of the lengthy post:

Transport Canada should no longer be allowed to continue to operate without being accountable for their actions – to the public, to industry and to the law.

If Transport Canada desires to change, break, ignore or enforce a law, they should have to answer for it.

If Transport Canada desires to implement a system which has been tried, and has FAILED, in other industries, this should be done in a careful, joint effort with industry, in an accountable and transparent way, and in partnership with a solid and effective oversight system.

Companies would be well encouraged to implement SMS of their own volition. Customers could be encouraged to make their purchasing decisions based on an operator’s SMS. (To accomplish the latter you would have to first find a way to dissuade customer support of the lowest bidder.)

You simply cannot legislate safety (or common sense). As I have said on many occasions, if everyone operated in accordance with the law, by default we would be well on the way to safety.

If one does not agree with a law, there is a system in place to change it – what right do people have to ignore some laws as frivolous or unimportant, but not others; as to them they are paramount? Our respective certificates do not give us the right to play god with people's lives.

The human race is not mature, nor open-mined and truthful enough to motivate and regulate itself. The only way to change this is to support those who are mature, open-minded and truthful; to continuously educate those around us; and to reward, not punish, those who are professional in their work.


______________________________________________
"Would you rather have an accident, or prevent the accident altogether? If it is the latter, then you should be an advocate for SMS." What kind of question is this? What does it mean? Pre SMS, had you asked the question, do you think the response would somehow be different?

"The people that made that choice [requiring SMS] 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. "
Well this is rather a big point isn’t it?! Not only did Transport Canada empower business aviation to regulate itself without the approval of Parliament (until a couple of years after the fact), they implemented random components of SMS in advance of Parliamentary approval for the concept, and now, most of industry has no oversight, and no SMS!

"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." So the fact that Transport Canada continues to act both outside the law, accountable to no-one and in accordance with its own self-serving policies and procedures which differ from region to region; should just be overlooked and forgotten – oh well?!

"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. " As I see it, TC is marching on in a disorderly and ineffective fashion, its diminishing inspectorate divided and confused. TC Bureaucracy has wasted a small fortune and vast amounts of time and effort on training courses, conferences and meetings to brief its inspectorate on how to understand a developing concept not empowered by law, and not clearly defined to themselves. Additional precious resources have been wasted, not in asking industry for input and consideration, but in educating the inspectorate as to the proper bafflegab and politispeak to bombard and browbeat industry into submission and compliance. Can you please clarify and/or quantify how you measure “real value”?

"The basic idea of SMS is that we as individuals and companies are responsible for our own safety. " Has this changed? How are we, as individuals, and companies not previously and presently responsible for our own safety, and the safety of those in our care? Does not a pilot license, engineering license or operating certificate already make you responsible?

"To the many who have complained about intrusive oversight, one would think that this would be just what we have wanted;" We don’t have any oversight!

"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?" Oversight has already left the building. SMS is not approved, only “validated” – therefore TC assumes no liability or responsibility for how a company self-regulates. Aside from a few brief Inquiries, the results of which were largely ignored, Transport Canada has never been under any real [public] scrutiny, nor are they accountable to anyone – so what system is in place under SMS to change this and make them suddenly accountable?

"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. " They will never be certified under the presently proposed system – there is no provision for “certification” or approval – only “validation” which means nothing.

"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. " Known bad operators (to industry and to Transport) continue to operate, and sometimes they crash and kill people. If Transport can’t, or won’t shut these operators down when they have the power to do so, how will a “validated operator” who is not subject to any audit, be shut down? Do you think they will shut themselves down? Why would they do that? Just like the criminal underworld, bad operators simply adapt to change – they will simply falsify beautiful paperwork and carry on – ops normal. When and if Transport Canada is legally empowered to absolve themselves of all liability and responsibility for industry, who is going to pull the operator’s certificate?!

"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."
What, gone because a piece of paper says it shall be gone? A piece of paper presently says though shalt not operate (pilot, or operator) an unserviceable airplane – in any weather!. The same lack of protection for those concerned with safety will still be there. Peer and operator pressure against a lone voice will not be gone.

___________________________

Again,
The human race is not mature, nor open-mined and truthful enough to motivate and regulate itself. The only way to change this is to support those who are mature, open-minded and truthful; to continuously educate those around us; and to reward, not punish, those who are professional in their work.


Best Regards,
Kirsten B.
http://safeskies.ca/mission.html

(edited because my passion got in the way of my proof-reading!)
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Last edited by snoopy on Sun Jun 21, 2009 10:56 am, edited 2 times in total.
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Re: SMS From Another Perspective

Post by Cat Driver »

But then again we could also dredge up all these posts on AvCanada to put together a pretty convincing insanity plea. :wink:
Maybe, but for that defense to work they could use the argument that if that old bastard is insane how in hell did he manage to beat our massive legal department in the inquiry into wrongdoing within the top structure of TCCA?

I bet you meant " temporary insanity " brought about by reading all those posts that were so factual that TC never found a way to put a stop to them.

Yeh, I can see that working because after all that effort even the strongest among us could slip. :mrgreen:
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Re: SMS From Another Perspective

Post by xsbank »

Good post, Snoopy.

Some people just don't get it - the only reason that Transport wants to 'convert' us all to SMS is because it benefits them in some way, not because we really need it. After all, doesn't Canada have "...the safest aviation whatnot/bullsh*t/whatever in the world..." then if that's true, why do we need SMS?

Safety goes without saying to the majority of us - I don't plan to go to work and die today, nor tomorrow. The accidents keep happening and the BS keeps flowing. If they really thought we have a problem (we do, TC just won't admit it) they would ask a few of us what we think about a solution, rather than ramming this BS down our throats and changing things to suit them.

I call this bullsh*t. Remember "Bullsh*t baffles Brains?" Make the TC changes, then we'll talk.
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Re: SMS From Another Perspective

Post by Cat Driver »

How many here think Prusse's replacement will bring about changes in how T.C. is managed?

Or to put it another way will he understand the the difference between morality and immorality?
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Re: SMS From Another Perspective

Post by Cat Driver »

What I would love to see is for George Sugar to put his eloquent use of the English language to work to find a way to do a complete enema of TCCA, then I will jump on board his efforts to embrace and support SMS in the small aircraft end of Canadian aviation.
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Re: SMS From Another Perspective

Post by Widow »

george sugar wrote: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.

<snip>

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.
Hi George,

Thank you for your empathy and admiration. As I ass.u.me you have gleaned, sparing other families the same heartache I’ve experienced is exactly why I take great interest in how TC oversees the industry.

IMHO, SMS would not have prevented the accident that took my husband. It would not have resulted in any lives being saved. It would not have resulted in any repercussions. After all, the operator had an SMS of sorts in place (as required by their contract with INTERFOR). The paperwork indicated that regulations and standards were followed. There was no paperwork to indicate otherwise, and when asked, wrongdoers denied.

If you can explain to me how SMS (and especially in light of the SUR replacing the FOIP) would have changed anything, I might be willing to cut TC some slack, as you have requested.

TC has "other priorities" than the non-airline sector of the industry. By failing to take into account the extreme differences between sectors, TC does an injustice to the whole concept of SMS.

As others have pointed out, unions and professional associations available to the airline industry help to mitigate some of the dangerous practices which may result from profit-motivated self-regulation. The idea of a Canadian College of Professional Pilots (or similar) is not a proffering to replace SMS, but to improve it's efficacy in the face of the issues noted.

In other words, many of us are not so much "fighting SMS", as encouraging improved methods of oversight and implementation.

Kirsten S.
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Re: SMS From Another Perspective

Post by snaproll20 »

WOW-sers!!!!!!!

I agree with the sentiments of Snoopy, SeptRepair, Clunk Driver, Widow, Sky's the Limit, Trey Kule, Pita, (and maybe some others) posting here.

but not George Sugar.


As a consequence, I will not repeat everything they have said.

After watching TC for almost 50 years, I am convinced that they are 'getting out of the game'. If they are not going to be involved, they should be disbanded. They are not doing their job under the Air Act.

All the time I have watched them., TC has dabbled in many things. I can barely remember ANYTHING they have carried to a successful conclusion.
Take MEL s for instance. 19 years of off-and-on dabbling and they finally gave up while the FAA has reams of information they could have rubber-stamped. I ranted at inspectors more than 20 year ago about putting together an official IFR Manual since they all had different ideas. Then we got one. Now it is not being amended, so is useless.

Stop dabbling, you damned tax-payer-wasteful bunch of hypocritical, useless, incompetent, irresponsible and confused IDIOTS!!!
Now, let me see..........how do I really feel?
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Re: SMS From Another Perspective

Post by Cat Driver »

I had the same feeling reading Snoopy's position on George Sugar's position on SMS.
With all due respect George, I wasn't going to respond to the original post which had the feel of bafflegab and politispeak,
Then again I am a mere commoner who does not move in the rarified air that the elite among us live in, so I have that human failing of being confused by bafflegab I prefer simple words that are easy to understand and can be read without falling asleep.
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Re: SMS From Another Perspective

Post by george sugar »

Well folks, it all sounds quite nihilistic, especially the one about “The human race is not mature, nor open-mined and truthful enough to motivate and regulate itself.” This sort of rhetoric gives credence to advocates of the nanny state, and might make one wonder if we should confer on individuals any kind of responsibility , much less the operation of an aircraft, until a condition of universal enlightenment dawns.

I have probably said enough here, and no doubt some think I took a long time to say nothing in the first place. And obviously my feeble ordnance is insufficient to penetrate some of the more hardened fortresses. But the new DGCA seems open-minded and approachable, as he certainly listened for a long time while we harangued him; and the SMS teams that I have been recently working with know the material, know the problems, and are sincere in their considerable efforts.

TC is improving, but they never have and never will run our companies and fly our airplanes, at any level of the industry. If we ever want to shake off the bleak veil of Snoopy’s assessment, we need to consider the possibility that some of those mature, open-minded and truthful people work at TC. If anything regulatory is ever going to work, whether under SMS or otherwise, we should keep in mind that common sense is not the exclusive domain of those that define themselves by saying "no" and "never" all of the time.

My sincere best wishes to all.
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Re: SMS From Another Perspective

Post by Cat Driver »

But the new DGCA seems open-minded and approachable,
I hope he is because I am going to request he have another look at my file and ask him when I can expect to receive the money that was to be given to me for the unlawful actions that were taken against me if my allegations regarding the last DGCA and a few other TCCA top managers were found to be true.

They were and I have yet to see a cent from TCCA.

As I have said in another thread I will post the letter I am writing him here on Avcanada.

So we shall see how open minded and approachable he is.

If he will not or claims he can not correct this issue then that should give everyone in aviation a good feel for what else he will or will not do.
we need to consider the possibility that some of those mature, open-minded and truthful people work at TC.
True but their efforts are demeaned by the thug mentality ones they don't seem to be able to get rid of.
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Re: SMS From Another Perspective

Post by 2R »

There are some slick dvds out there for SMS company indoctrination.If you get a chance to see one .It will clear all the mystery and misery of the SMS implementation.
I liked the old system of DFU much better :mrgreen: :mrgreen:

For entertainment :
You might say that Transport Canada has been trying to harmonize the air safety system with that of our largest trading partner to the south.As have most government deptments been busy harmonizing .
The USA had Alphabet airspace
Canada followed and now has Alphabet airspace
The USA had FARS
Canada followed and now has CARS
The USA has had SMS for years
Canda has followed again and now has SMS
The USA is not happy with its' present system of SMS and is in the rapid process of replacing it .The FAA has its marching orders from Congress and the promulgation process has begun.The hiring programme for Enforcers has begun
Will Canada follow?
In the true spirit of North American harmonization and as we all melt into that gelatinous mass they will have to follow us in the US.Just as Canada followed Britains lead of the National Health Service act of 1947 they quickly brought in health care in 1967.The Americans may just be the last industrialized nation in the G8 to get the economic advantage of a national health care system by at least 2017 on the present track.Maybe we will be implementing the new and improved SMS in the same time frame :mrgreen:
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Re: SMS From Another Perspective

Post by Rockie »

Cat Driver wrote:What I would love to see is for George Sugar to put his eloquent use of the English language to work to find a way to do a complete enema of TCCA, then I will jump on board his efforts to embrace and support SMS in the small aircraft end of Canadian aviation.
George won't do that because his income flows from his position as VP Cargojet. His job is to ensure his company operations and TC have a meeting of minds, not bucking the system. If he pushed hard to change things his job is threatened, so why would he do that? I don't really know why he's such a vocal advocate of SMS on this forum anyway because in that respect he's preaching to the choir, and we're not the people that have to be convinced. If he really wanted to push this he would have a sit down with people like Michel Leblanc and state his case. Asking people on this forum if they're in favour of safety is like asking a Sudanese if they're in favour of an end to hunger.
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Re: SMS From Another Perspective

Post by FlowPack »

It's been said, 'paper trails exist to make a case, not to tell the truth.'
To certain companies, SMS is just more paper.
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Re: SMS From Another Perspective

Post by snaproll20 »

heck, even the inspectors don't agreewith how it is being implemented.
Sorry George, but like someone said, you are preaching to the choir. We just don't need another rule.

Most of the safety improvements in recent years have come from responsible managers using some kind of SMS. I would be reluctant to say TC had any major role that was recognizable.
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Re: SMS From Another Perspective

Post by Cat Driver »

George won't do that because his income flows from his position as VP Cargojet. His job is to ensure his company operations and TC have a meeting of minds, not bucking the system.


Yes Rockie I am aware of what George does for a living, and I am wondering why he thinks that trying to approach the 703 sector of aviation using the bureaucrat speak style of writing will resonate among that group?
If he pushed hard to change things his job is threatened, so why would he do that?
I have no idea, except maybe his style is don't rock the boat if you think it will not be in your own personal best interest?

In other words I'm damned if I know what his motivation is. Judging from the way this thread is going he has a real challenge trying to change the mindset here however his job probably will not be threatened by TC for his position on this, in fact he may be offered a job by them.
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Re: SMS From Another Perspective

Post by Widow »

Hi George,

I hope you will not desert the thread, as this has stimulated some good discussion, and could do much more.

We can all be guilty of using flowery words and affective phraseology to get our points across, you included! I don’t think the dawn of universal enlightenment is needed to go forth! :wink:

As others have pointed out, aviation is a very unique industry. And the airline sector very different from the non-airline sectors, especially with respect to the kinds of issues that will be faced on a day to day basis by workers at any level of the organization – the protections and avenues of redress available.

Your experience seems to be with the airline sector, and I am not surprised that you feel good about the way it is going. The airline sector is much more heavily regulated, TC has a keen interest in prioritizing airline issues (potential body count) and unions/professional associations help to keep the money/safety balance in check. Despite the suspicion shown in some posts about your ulterior motives, I suspect you only wished to share that your experience has been good, and hoped to provide a learning opportunity to others. This is a very sensitive subject for those outside the airlines, and quite understandably, hackles go up when it is suggested that a refusal to accept TC's SMS implementation is indicative of not wanting to be safe.

I feel that you – and Transport Canada – are ignoring the stark differences between the industry sectors, and that ignoring those differences is not going to make them go away. I, and apparently others, believe the existing problems need to be addressed before SMS can be safely implemented into the non-airline sectors.

Perhaps of greater value than trying to refute the concerns, would be to lend your thoughts about how these issues (and perhaps you would just have to accept our concerns at face value, whether you agree or not) could best be addressed by the system, and how SMS could be made to work within the non-airline sectors.

I am pleased that you have found the new DGCA to be receptive, and that your “SMS team” from TC has been both knowledgeable and helpful. The experience by many in the air taxi/non-airline sectors has not been so good. I hope that your experience is indicative of a “cultural shift” within TC itself.

Personally, I would be interested to know when your company began to adopt SMS, what problems arose along the way and how they were solved, how the unions may have been involved in the process, whether audits and inspections have continued and how your company has been graded during the validation process.

One of my favourite SMS critics has told me, SMS is here to stay, like it or not. In the face of that, the best options, in my mind, revolve around how to address the problems before they result in more bodies.

Stay safe,
Kirsten S.

PS. Rockie - Please tell me Michel Leblanc isn't still at it? I had a good laugh over the short but sweet wiki entry.
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Re: SMS From Another Perspective

Post by Rockie »

Widow

To my knowledge Leblanc is no longer involved (at least directly) in aviation in Canada. However, a person with his resourcefulness and scruples can find many ways to take advantage of a good thing without having their name attached so I rule nothing out. The real problem is that there is no shortage of people like him in every sector of this industry, and that's why SMS without robust oversight is a danger to the public as far as I'm concerned. It is akin to giving the fox the keys to the henhouse.

The most meaningless term in SMS is "accountable executive". It begs the questions: accountable to whom?, and accountable in what way? Under the old system TC would not shut down the Leblanc's, so why should we believe they would do anything about them now when they are stepping even further back from the lousy regulatory job they were doing before?
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george sugar
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Re: SMS From Another Perspective

Post by george sugar »

We should lament that we have come to the day where the use of compound sentences and polysyllabic words leaves one open to charges of bafflegab and bureaucrat-speak, but I recognize that this is so and remain willing to take the barbs hurled at the beloved English language.

A number of points in your post Kirsten give me cause for hope. I do not have ulterior motivation for sharing my experience, and do indeed wish to provide a learning opportunity to others. My purpose was not to refute widely held concerns, merely to indicate that the positive changes desired by everyone here have begun to appear. I seek to bolster your efforts rather than negate them.

Industries and sectors within industries are different, and the regulator is most certainly different from the regulated; I have never contended otherwise. That is not say that some positive elements and ideas cannot cross these divides. There is progress in all camps and mature adults can always work together for a solution. It has been amply demonstrated that working co-operatively almost always yields better overall results than name-calling and grudge matches. It would be a shame to trample the nascent development of a positive trend because a wholesale change has not occurred all at once.

This overall SMS discussion should definitely continue, but others should be given the opportunity to participate, so I won’t take up any more valuable column-inches than I have. I would be pleased to speak or correspond with you or anyone else directly to discuss the points raised, in the shared goal of a safer and more efficient aviation industry.

Best regards,

George
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Sidebar
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Re: SMS From Another Perspective

Post by Sidebar »

George,

Good topic!

I think SMS is a great concept. However, putting the concept into operation is much more easily done for large organizations (ie 705) than it will be for small air taxi outfits that only have one or two planes and a small staff who wear multiple hats as owner/Ops Mgr/PRM/CP/Safety Mgr...

Some operators will do it well and benefit, and some will have nothing but a binder on the shelf they can point to.

Before many 703 operators have put SMS in place, TC has mostly withdrawn from any meaningful oversight of industry segments that do not yet have SMS. TC says they are still conducting oversight, but I think they are living in a state of denial. IMHO, this is a major problem and likely to contribute to accidents.

Don't let the negative tone of the responses get you down. Although your initial post reads like a cheerleader for TCCA, you've opened a good discussion.
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trey kule
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Re: SMS From Another Perspective

Post by trey kule »

It has been amply demonstrated that working co-operatively almost always yields better overall results than name-calling and grudge matches
....and when you co-operate with tyranny, you become a slave. Please think for just a moment, what co-operation means to the regulator. It means you accept the fact that they have gone ahead with insufficient planning as to implementation, and we are supposed to accept that...c0-operate if you will. Now ask the regulator to co-operate by going back and thinking things through a little more thorougly before rushing ahead and see how this co-operation will work. It is one sided, and it amounts to doing what the regulator wants regardles of any failure on their part to do their job properly...just accept it. I dont know how many times I have heard TC people in the past admit "we know there is problems ...but move ahead"
Not just SMS but over the years a whole raft of issues that they subsequently did a 180 on ....after a few years of failing to co-operate with the industry.

No one here is arguing the principle is in error. Not one that I can see. The problem with the whole thing is with the regulator and advising people to accept that it is here and get on with the process. It is really irresponsible for someone so experienced in the industry ( my opinion) to preach mindless acceptance of a flawed system..and it is flawed for the small operator. Where does one draw the line when it comes to ill thought out implementation plans, and even general concepts, by a regulator? Or do we just mindlessly accept it and c0-operate?

In reading all the responses I think it fair to say that one size SMS does not fit all. When you have a 100 people working in an organization, you need rigid formalization. When you have one or two pilots, one engineer, and one ot two other staff, things can effectively be done much more informally (and equivalently), and thus the imposition of the formalization that TC is trying to bring about will take one of two paths. Outright resistance, or pencil whipping the paper. It is a fact of life.

I think also, like some of the others, I found some of your original post a little difficult to swallow. As mentioned before, because I do not embrace the TC version of SMS does not mean I wish not to be safe as possible. It is hard not to be offended when someone or some organization uses this type of logic. Please accept my apologies George, for my reply as it appears as I understand you simply did not wish to insult me with the doublespeak logic in some of your posts.
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