dhc2widow
28th May 2007, 17:40
Some of you may be following, with interest, the procedings of the Standing Committee on Transportation, Infrastructure and Communities and it's discussions regarding Bill C-6, An Act to Amend the Aeronautics Act. This is a presentation which was given to the Committee on May 14th. The full transcript is available here: May 14th SCTIC Transcript (http://http://cmte.parl.gc.ca/cmte/CommitteePublication.aspx?SourceId=207542&Lang=1&PARLSES=391&JNT=0&COM=10462).
Mr. Paul Carson (Flight Technical Inspector, Certification and Operational Standards, Transport Canada, As an Individual):
Thank you very much.
I'm going to read initially from what I've written. It's a little longer than seven minutes, but I'll cut it short.
I would like to personally thank the steering committee for taking the time to let me appear before you today to express my ideas. It should be made clear that I am here on my own accord, speaking as Citizen Carson, not Inspector Carson, or Captain Carson, or Dr. Carson--all of these euphemisms we attach to ourselves to make it easier for others to deal with us.
It should also be made clear that I personally am a believer in safety first and pretty much everything else second, including profit. I can unequivocally state that I am a supporter of concepts like SMS.
First, what is my background? It includes about 40 years of work experience, 30 of them in aviation; four university degrees, one in aeronautical engineering, including a PhD in applied math; approximately 10,000 hours of flying, all civilian, including for two prime ministers and several CEOs of a couple of Canada's largest corporations. I have been any number of things in my aviation career, including flight safety officer and occupational health and safety officer at a couple of companies. Many years ago I took a course on system safety at the University of Southern California in San Diego, and just recently I took TCCA's course on SMS.
SMS is not a new concept. It has been around in various forms for many years. There are many things about an SMS program that would be highly beneficial. It is certainly a better idea to have everyone in any organization safety conscious instead of vesting that job solely in an individual like me, for example, with minimal staff, as many air operators have done in the past.
Having the onus put on an organization to have them operate within a safety-minded culture is certainly better than operating any other way. However, although the concept of safety in itself can mean very specific things, it is sort of like a religion: you either believe in it or you don't. By that I mean you either believe you can operate safely within the rules and do the job cost effectively or you believe the rules you have been asked to follow are merely suggestions and the only thing that matters is the bottom line. Safety is expensive. Far too many aviation companies believe the regulations are just that, guidelines, and it is okay to bend them to the limit, if not outright break them, as long as nothing goes wrong or you don't get caught.
Hence the subject of my visit. In front of you today is something that I think is missing, in part, in order to make SMS work. And I would like to see it work.
Pilots need a nationwide self-governing, self-regulating professional association to which all professional pilots--and I mean those flying for hire or reward--must belong. In view of the changes presently occurring in the aviation industry with the introduction of SMS--a form of what I like to call “supervised” self-government and self-regulation for the air operator industry--they need it to provide a pilot input to balance company management, government regulators, and clients in the dynamic bargaining process that determines the industry environment. They need it to provide them with real whistle-blowing protection, since they will be the ones under SMS who really know what will be going on in the future, in my opinion. They need it to set standards for technical education required for the various types of aviation jobs, from entry-level commercial pilot to captain of high-performance passenger-carrying jet. They need it to ensure they receive the proper ongoing education to enable them to do each job with confidence and competence as they progress through their careers. Ethics will be taught and examined.
When I first wrote this paper, I talked only about pilots, since I am a pilot, but I would now extend the same concept to licensed maintenance engineers and certificated dispatchers. Also, for the record, I sent my ideas twice through TCCA's issues reporting system, and then in the form of a discussion paper to my current director and to the association to which I belong. So I have tried to communicate with a number of people.
What is missing from SMS is a check and balance system, in my opinion. It is one thing to give supervised self-government and self-regulation to an air operator, to the management, and the owners of a company, but it is an oversight not to give the same thing to the licensed pilots, maintenance engineers, and dispatchers who do the work. For example, without the licensed pilots employed by the company, the company cannot operate. These licensed individuals need their own self-governing, self-regulating association that will provide them the protection they very much need from any unscrupulous employer on those occasions when an employee feels the need to blow the whistle on the company for safety violations. We've had incidents of this in the past, recently in Toronto. This body needs to be the licensing authority for these individuals, not the governing authority, in my opinion.
http://cmte.parl.gc.ca/common/images/arrow2_down.gif (http://cmte.parl.gc.ca/cmte/CommitteePublication.aspx?SourceId=207542&Lang=1&PARLSES=391&JNT=0&COM=10462#T1540) http://cmte.parl.gc.ca/common/images/arrow2_up.gif (http://cmte.parl.gc.ca/cmte/CommitteePublication.aspx?SourceId=207542&Lang=1&PARLSES=391&JNT=0&COM=10462#T1530)(1535) (http://cmte.parl.gc.ca/cmte/CommitteePublication.aspx?SourceId=207542&Lang=1&PARLSES=391&JNT=0&COM=10462#TOC-TS-1535)
Other professions have self-regulating associations that influence the environment their members work in, set professional qualification standards, and continue to judge their professional competency. Such professional associations also intervene on behalf of their members or the general public, if necessary, when there are security and safety concerns. Engineers, doctors, and lawyers all have self-regulating associations, as do other professions.
Anyone who wishes to practise one of these professions must satisfy the standards set by the association and must be a member in good standing. These associations also discipline members who have failed to meet the obligations and responsibilities of their profession. No one gets a free ride.
Regarding common interests, many professional pilots—again, those who use their licence to fly for hire or reward—have no opportunity to belong to any association. I'm aware of only three major trade associations for pilots in Canada: the Canadian Federal Pilots Association, for pilots employed by the federal Department of Transport, to which I belong; the Air Line Pilots Association, Canada, ALPA Canada, for pilots employed by various regional airlines; and the Air Canada Pilots Association, ACPA, for a grand total of approximately 4,000 pilots.
The last time I checked, over 19,000 aviation licences, belonging to commercial and airline transport pilots, are in force in Canada, enabling their holders to offer their services as professional pilots. The vast majority of professional Canadian pilots, who work as flight instructors, bush pilots, charter pilots, corporate pilots, agricultural spray pilots, air ambulance pilots, or any other of the many varieties of flying jobs in aviation, have no professional association.
I could go on at length; I'm limited in my time here.
For those who belong to a professional association, say, regarding the law.... If you read this section on education, you'll understand a lot more about where I'm coming from because this forms a lot of it. It's a couple of pages, and I have to skip over to a section entitled, “Other Functions”. If you read that, then you'll appreciate the next comment.
I dealt at length with knowledge and licensing as a responsibility of the proposed professional pilots association, because I feel it is the foundation upon which any claim to professionalism must be made. That's essential. However, besides knowledge and licensing, the professional pilots association would take responsibility for representing pilots and providing specialist assistance—say, in accident investigation—and for encouraging and even sponsoring research into airframe, engine, and system design, and into the civic aspects of aviation personnel management and interpersonal behaviour, something that today we call the human factors.
Another important function would be presenting the pilots' point of view as a group on proposed legislative changes, as part of the consultation process with industry owners and operators. Company management is judged by whether they show a profit at the end of the year. While pilots are by no means immune to the profit motive, they are also aware that the high salaries they may earn mean little when you arrive first at the scene of an accident.
Membership in a professional pilots association must be mandatory for all pilots who fly for hire or reward, just as professional engineers must belong to their provincial professional association if they are paid for their services as engineers. Such professional membership must be a legal, regulatory requirement with no waivers or exceptions possible. Voluntary membership in a professional association would not be sufficient.
In conclusion, to accomplish the changes I have suggested will take organization, experience dealing with government, and certainly familiarity with the aviation industry, at the very least. The existing pilots trade associations could act as the nucleus around which a professional association, such as I have outlined above, could grow.
A professional association also needs legal status. We must have a federal professional pilots act, or something similar, to give the association legal existence and the powers it will need.
As well, federal empowerment will address our obligations under the Convention on International Civil Aviation. The remaining requirements would be hard work and some dedication.
Thank you for listening.
Mr. Paul Carson (Flight Technical Inspector, Certification and Operational Standards, Transport Canada, As an Individual):
Thank you very much.
I'm going to read initially from what I've written. It's a little longer than seven minutes, but I'll cut it short.
I would like to personally thank the steering committee for taking the time to let me appear before you today to express my ideas. It should be made clear that I am here on my own accord, speaking as Citizen Carson, not Inspector Carson, or Captain Carson, or Dr. Carson--all of these euphemisms we attach to ourselves to make it easier for others to deal with us.
It should also be made clear that I personally am a believer in safety first and pretty much everything else second, including profit. I can unequivocally state that I am a supporter of concepts like SMS.
First, what is my background? It includes about 40 years of work experience, 30 of them in aviation; four university degrees, one in aeronautical engineering, including a PhD in applied math; approximately 10,000 hours of flying, all civilian, including for two prime ministers and several CEOs of a couple of Canada's largest corporations. I have been any number of things in my aviation career, including flight safety officer and occupational health and safety officer at a couple of companies. Many years ago I took a course on system safety at the University of Southern California in San Diego, and just recently I took TCCA's course on SMS.
SMS is not a new concept. It has been around in various forms for many years. There are many things about an SMS program that would be highly beneficial. It is certainly a better idea to have everyone in any organization safety conscious instead of vesting that job solely in an individual like me, for example, with minimal staff, as many air operators have done in the past.
Having the onus put on an organization to have them operate within a safety-minded culture is certainly better than operating any other way. However, although the concept of safety in itself can mean very specific things, it is sort of like a religion: you either believe in it or you don't. By that I mean you either believe you can operate safely within the rules and do the job cost effectively or you believe the rules you have been asked to follow are merely suggestions and the only thing that matters is the bottom line. Safety is expensive. Far too many aviation companies believe the regulations are just that, guidelines, and it is okay to bend them to the limit, if not outright break them, as long as nothing goes wrong or you don't get caught.
Hence the subject of my visit. In front of you today is something that I think is missing, in part, in order to make SMS work. And I would like to see it work.
Pilots need a nationwide self-governing, self-regulating professional association to which all professional pilots--and I mean those flying for hire or reward--must belong. In view of the changes presently occurring in the aviation industry with the introduction of SMS--a form of what I like to call “supervised” self-government and self-regulation for the air operator industry--they need it to provide a pilot input to balance company management, government regulators, and clients in the dynamic bargaining process that determines the industry environment. They need it to provide them with real whistle-blowing protection, since they will be the ones under SMS who really know what will be going on in the future, in my opinion. They need it to set standards for technical education required for the various types of aviation jobs, from entry-level commercial pilot to captain of high-performance passenger-carrying jet. They need it to ensure they receive the proper ongoing education to enable them to do each job with confidence and competence as they progress through their careers. Ethics will be taught and examined.
When I first wrote this paper, I talked only about pilots, since I am a pilot, but I would now extend the same concept to licensed maintenance engineers and certificated dispatchers. Also, for the record, I sent my ideas twice through TCCA's issues reporting system, and then in the form of a discussion paper to my current director and to the association to which I belong. So I have tried to communicate with a number of people.
What is missing from SMS is a check and balance system, in my opinion. It is one thing to give supervised self-government and self-regulation to an air operator, to the management, and the owners of a company, but it is an oversight not to give the same thing to the licensed pilots, maintenance engineers, and dispatchers who do the work. For example, without the licensed pilots employed by the company, the company cannot operate. These licensed individuals need their own self-governing, self-regulating association that will provide them the protection they very much need from any unscrupulous employer on those occasions when an employee feels the need to blow the whistle on the company for safety violations. We've had incidents of this in the past, recently in Toronto. This body needs to be the licensing authority for these individuals, not the governing authority, in my opinion.
http://cmte.parl.gc.ca/common/images/arrow2_down.gif (http://cmte.parl.gc.ca/cmte/CommitteePublication.aspx?SourceId=207542&Lang=1&PARLSES=391&JNT=0&COM=10462#T1540) http://cmte.parl.gc.ca/common/images/arrow2_up.gif (http://cmte.parl.gc.ca/cmte/CommitteePublication.aspx?SourceId=207542&Lang=1&PARLSES=391&JNT=0&COM=10462#T1530)(1535) (http://cmte.parl.gc.ca/cmte/CommitteePublication.aspx?SourceId=207542&Lang=1&PARLSES=391&JNT=0&COM=10462#TOC-TS-1535)
Other professions have self-regulating associations that influence the environment their members work in, set professional qualification standards, and continue to judge their professional competency. Such professional associations also intervene on behalf of their members or the general public, if necessary, when there are security and safety concerns. Engineers, doctors, and lawyers all have self-regulating associations, as do other professions.
Anyone who wishes to practise one of these professions must satisfy the standards set by the association and must be a member in good standing. These associations also discipline members who have failed to meet the obligations and responsibilities of their profession. No one gets a free ride.
Regarding common interests, many professional pilots—again, those who use their licence to fly for hire or reward—have no opportunity to belong to any association. I'm aware of only three major trade associations for pilots in Canada: the Canadian Federal Pilots Association, for pilots employed by the federal Department of Transport, to which I belong; the Air Line Pilots Association, Canada, ALPA Canada, for pilots employed by various regional airlines; and the Air Canada Pilots Association, ACPA, for a grand total of approximately 4,000 pilots.
The last time I checked, over 19,000 aviation licences, belonging to commercial and airline transport pilots, are in force in Canada, enabling their holders to offer their services as professional pilots. The vast majority of professional Canadian pilots, who work as flight instructors, bush pilots, charter pilots, corporate pilots, agricultural spray pilots, air ambulance pilots, or any other of the many varieties of flying jobs in aviation, have no professional association.
I could go on at length; I'm limited in my time here.
For those who belong to a professional association, say, regarding the law.... If you read this section on education, you'll understand a lot more about where I'm coming from because this forms a lot of it. It's a couple of pages, and I have to skip over to a section entitled, “Other Functions”. If you read that, then you'll appreciate the next comment.
I dealt at length with knowledge and licensing as a responsibility of the proposed professional pilots association, because I feel it is the foundation upon which any claim to professionalism must be made. That's essential. However, besides knowledge and licensing, the professional pilots association would take responsibility for representing pilots and providing specialist assistance—say, in accident investigation—and for encouraging and even sponsoring research into airframe, engine, and system design, and into the civic aspects of aviation personnel management and interpersonal behaviour, something that today we call the human factors.
Another important function would be presenting the pilots' point of view as a group on proposed legislative changes, as part of the consultation process with industry owners and operators. Company management is judged by whether they show a profit at the end of the year. While pilots are by no means immune to the profit motive, they are also aware that the high salaries they may earn mean little when you arrive first at the scene of an accident.
Membership in a professional pilots association must be mandatory for all pilots who fly for hire or reward, just as professional engineers must belong to their provincial professional association if they are paid for their services as engineers. Such professional membership must be a legal, regulatory requirement with no waivers or exceptions possible. Voluntary membership in a professional association would not be sufficient.
In conclusion, to accomplish the changes I have suggested will take organization, experience dealing with government, and certainly familiarity with the aviation industry, at the very least. The existing pilots trade associations could act as the nucleus around which a professional association, such as I have outlined above, could grow.
A professional association also needs legal status. We must have a federal professional pilots act, or something similar, to give the association legal existence and the powers it will need.
As well, federal empowerment will address our obligations under the Convention on International Civil Aviation. The remaining requirements would be hard work and some dedication.
Thank you for listening.