SMS - Improving airline safety or not?
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SMS - Improving airline safety or not?
Given that JAA/EASA is going the same way as Transport Canada (see the article below), self-regulation by the airlines is a great idea and will improve overall aviation safety. Discuss.
New rules for aviation safety a flight plan to disaster, critics warn
By Terri Theodore (CP) – Aug 23, 2009
VANCOUVER, B.C. — Proponents predict it will make air travel in Canada safer than ever. Critics call it a flight plan for disaster.
A controversial new regulatory system that forces the aviation industry to enforce its own safety standards has some accusing Ottawa of abdicating responsibility for ensuring the safety of Canadian passengers, citing tragic experiences in Canada's rail industry as cautionary tales.
For nearly a decade, rail safety in Canada has been governed by a so-called safety management system. Companies are responsible for devising their own safety plans according to regulatory standards and must ensure that their day-day operations conform.
During that period, however, several accidents took place that were blamed on faulty rail-safety systems, including a runaway train in 2006 that killed two railway workers.
"It's like the fox running the henhouse," said Virgil Moshansky, a former judge whose investigation into the deadly Air Ontario crash in 1989 in the northwestern Ontario town of Dryden, led to major changes in Canada's aviation industry.
"It seems that Transport Canada, or the government, or both, need a major disaster to happen before they take action."
Moshansky headed up the inquiry that probed the crash that killed 24 people when ice buildup on the wings sent the plane careening into the ground, where it burst into flames and broke apart.
As part of the changes, a federal program to audit airline safety procedures has been cancelled and Transport Canada intends to stop regulating the frequency of inspections.
Transport Canada inspectors won't enforce safety regulations for companies with their own safety management systems. They will simply inspect safety reports written by the companies themselves.
Federal legislation that would have enshrined the changes into law - opposition parties aggressively opposed the bill - died when last year's federal election was called. The changes will instead be made through regulations, which do not require the approval of Parliament.
That will leave it up to aviation companies to devise their own safety policies, identify risks and make employees aware of the need for safety.
Proponents of the safety-management doctrine say that's the point.
By requiring airlines to create and police their own safety systems, with regulatory authorities as the backup, safety measures are enhanced, rather than diminished, they argue.
The International Civil Aviation Organization, a United Nations agency considered the international authority on civil aviation, notes that when such a system is working properly, it adds an extra layer of safety.
The ICAO has developed safety-system guidelines for nearly 200 member countries, including Canada, which is considered one of the leaders in its implementation.
Under the plan, operators, manufacturers, regulatory bodies and investigative agencies work together in a proactive, preventative system at all levels of an operation.
In Canada, large airline operators, their maintenance companies, principal airports and air traffic controllers already operate that way, said Chris Day, press secretary for Transportation Minister John Baird.
Small operators, their maintenance providers, flight training operations, companies that certify aircraft and aircraft makers will soon follow, with Transport Canada expecting the system to be fully implemented by 2015.
"This is about promoting safety, limiting risk, preventing incidents before they happen," said Day.
The regulations are being changed to match what's happening already, he added.
But even as the airline industry grows, there are fewer and fewer government inspectors.
"They (Transport Canada) have delegated the oversight function and enforcement function to the airlines themselves," Moshansky said.
Critics agree that airlines and railways must take principal responsibility for making sure passengers and crew are safe. But they also need the support of Transport Canada inspections and audits, they say.
The unions that represent Canada's inspectors say the system is being used as an excuse to reduce their numbers and to remain at arm's length from liability after accidents.
Kerry Williams, national vice-president with the Union of Canadian Transportation Employees, said there are 130 inspector positions vacant in Canada.
"This is one way to eliminate those vacancies in the stroke of a pen."
The number of inspectors over the last few years has dropped by 15 per cent while the aviation industry has grown by 50 per cent, reducing the role of inspectors to little more than "box tickers," he added.
Greg Holbrook, the chairman of the Canadian Federal Pilots Association, which represents pilot inspectors, said the government saw the system as a money-saver from the start.
"Really, what (this) is all about is about getting Transport (Canada) off the hook," Holbrook said.
"They haven't been able to do their job for a number of years because they don't have enough people and they don't have enough money to do it."
A Transport Canada plan backs up that claim.
Written eight years ago, the document says relying on companies for safety systems cuts costs and jobs and results in less "regulatory burden, Crown liability, oversight requirements."
Said Moshansky: "It seems that safety always gives way to the bottom line with Transport Canada. There are countless examples of this."
Baird himself wasn't available for an interview, but Transport Canada spokesman Brad McNulty said the agency is confident the program will only improve safety.
"Transport Canada is confident (safety management systems) will help save lives by preventing accidents," he said in an email to The Canadian Press.
That confidence isn't borne out by the experience of the rail industry.
The Transportation Safety Board, which investigates rail, air and marine incidents, has cited several accidents that were a direct result of a breakdown in that industry's self-managed safety system.
Tom Dodd and Don Falkner clung to a runaway CN train equipped with ineffective brakes as it plunged over a British Columbia cliff three years ago, taking them to their deaths.
The safety board concluded earlier this year that the choice of an engine with brakes not meant for mountainous terrain was made for "financial reasons, rather than safety reasons," contrary to the railway's own policy.
In August 2005, a defective rail set off an environmental disaster in Wabamun Lake west of Edmonton when 700,000 litres of thick crude oil spilled into the lake. The board criticized CN's rail maintenance and its dangerous goods emergency response plan in a report on the derailment.
Just days later, a train derailed along the Cheakamus River near Squamish, B.C., spilling caustic soda into the river, killing hundreds of thousands of fish. Again, the board blamed violations of the safety management system.
CN's policies were also cited as a factor in a fiery wreck in August 2007 in Prince George, B.C., and in a January 2007 derailment in Montmagny, Que., when four cars containing sulphuric acid derailed, but didn't spill.
A review of the industry's safety management policy released in 2008 concluded that the implementation of the policy had been inconsistent across the country and said Transport Canada hadn't dedicated enough resources to oversee it.
Federal auditor general Sheila Fraser also warned the government in a 2008 report that Transport Canada's transition to aviation safety management systems "had several weaknesses."
Fraser said the department didn't forecast expected costs for the transition, document potential risks or suggest mitigating actions and had no plan in place to evaluate the impact. She also warned there was no strategy in place to hire specialized people with skills gained on the job.
As a result of the recommendations in the rail safety review, McNulty said Transport Canada would be hiring 20 more inspectors for rail over the next three years.
While there are only a few dozen rail companies operating in Canada, there are more than 2,300 air operators certified to fly here.
Emilie Therien, past president of the Canada Safety Council, said the safety change in the airline industry will make Transport Canada a "toothless tiger" when it comes to enforcing safety.
"The safety level established by the carrier - whether it's rail or air - may not be the same one that was established by Transport Canada before," he said in an interview.
Hugh Danford, a former civil aviation inspector for the department, agreed, saying aviation travel is about profit and there's always a balance between money and safety.
"And that's why the (safety management system) won't work because they're putting that balance in the hands of the people who profit."
Copyright © 2009 The Canadian Press. All rights reserved.
By Terri Theodore (CP) – Aug 23, 2009
VANCOUVER, B.C. — Proponents predict it will make air travel in Canada safer than ever. Critics call it a flight plan for disaster.
A controversial new regulatory system that forces the aviation industry to enforce its own safety standards has some accusing Ottawa of abdicating responsibility for ensuring the safety of Canadian passengers, citing tragic experiences in Canada's rail industry as cautionary tales.
For nearly a decade, rail safety in Canada has been governed by a so-called safety management system. Companies are responsible for devising their own safety plans according to regulatory standards and must ensure that their day-day operations conform.
During that period, however, several accidents took place that were blamed on faulty rail-safety systems, including a runaway train in 2006 that killed two railway workers.
"It's like the fox running the henhouse," said Virgil Moshansky, a former judge whose investigation into the deadly Air Ontario crash in 1989 in the northwestern Ontario town of Dryden, led to major changes in Canada's aviation industry.
"It seems that Transport Canada, or the government, or both, need a major disaster to happen before they take action."
Moshansky headed up the inquiry that probed the crash that killed 24 people when ice buildup on the wings sent the plane careening into the ground, where it burst into flames and broke apart.
As part of the changes, a federal program to audit airline safety procedures has been cancelled and Transport Canada intends to stop regulating the frequency of inspections.
Transport Canada inspectors won't enforce safety regulations for companies with their own safety management systems. They will simply inspect safety reports written by the companies themselves.
Federal legislation that would have enshrined the changes into law - opposition parties aggressively opposed the bill - died when last year's federal election was called. The changes will instead be made through regulations, which do not require the approval of Parliament.
That will leave it up to aviation companies to devise their own safety policies, identify risks and make employees aware of the need for safety.
Proponents of the safety-management doctrine say that's the point.
By requiring airlines to create and police their own safety systems, with regulatory authorities as the backup, safety measures are enhanced, rather than diminished, they argue.
The International Civil Aviation Organization, a United Nations agency considered the international authority on civil aviation, notes that when such a system is working properly, it adds an extra layer of safety.
The ICAO has developed safety-system guidelines for nearly 200 member countries, including Canada, which is considered one of the leaders in its implementation.
Under the plan, operators, manufacturers, regulatory bodies and investigative agencies work together in a proactive, preventative system at all levels of an operation.
In Canada, large airline operators, their maintenance companies, principal airports and air traffic controllers already operate that way, said Chris Day, press secretary for Transportation Minister John Baird.
Small operators, their maintenance providers, flight training operations, companies that certify aircraft and aircraft makers will soon follow, with Transport Canada expecting the system to be fully implemented by 2015.
"This is about promoting safety, limiting risk, preventing incidents before they happen," said Day.
The regulations are being changed to match what's happening already, he added.
But even as the airline industry grows, there are fewer and fewer government inspectors.
"They (Transport Canada) have delegated the oversight function and enforcement function to the airlines themselves," Moshansky said.
Critics agree that airlines and railways must take principal responsibility for making sure passengers and crew are safe. But they also need the support of Transport Canada inspections and audits, they say.
The unions that represent Canada's inspectors say the system is being used as an excuse to reduce their numbers and to remain at arm's length from liability after accidents.
Kerry Williams, national vice-president with the Union of Canadian Transportation Employees, said there are 130 inspector positions vacant in Canada.
"This is one way to eliminate those vacancies in the stroke of a pen."
The number of inspectors over the last few years has dropped by 15 per cent while the aviation industry has grown by 50 per cent, reducing the role of inspectors to little more than "box tickers," he added.
Greg Holbrook, the chairman of the Canadian Federal Pilots Association, which represents pilot inspectors, said the government saw the system as a money-saver from the start.
"Really, what (this) is all about is about getting Transport (Canada) off the hook," Holbrook said.
"They haven't been able to do their job for a number of years because they don't have enough people and they don't have enough money to do it."
A Transport Canada plan backs up that claim.
Written eight years ago, the document says relying on companies for safety systems cuts costs and jobs and results in less "regulatory burden, Crown liability, oversight requirements."
Said Moshansky: "It seems that safety always gives way to the bottom line with Transport Canada. There are countless examples of this."
Baird himself wasn't available for an interview, but Transport Canada spokesman Brad McNulty said the agency is confident the program will only improve safety.
"Transport Canada is confident (safety management systems) will help save lives by preventing accidents," he said in an email to The Canadian Press.
That confidence isn't borne out by the experience of the rail industry.
The Transportation Safety Board, which investigates rail, air and marine incidents, has cited several accidents that were a direct result of a breakdown in that industry's self-managed safety system.
Tom Dodd and Don Falkner clung to a runaway CN train equipped with ineffective brakes as it plunged over a British Columbia cliff three years ago, taking them to their deaths.
The safety board concluded earlier this year that the choice of an engine with brakes not meant for mountainous terrain was made for "financial reasons, rather than safety reasons," contrary to the railway's own policy.
In August 2005, a defective rail set off an environmental disaster in Wabamun Lake west of Edmonton when 700,000 litres of thick crude oil spilled into the lake. The board criticized CN's rail maintenance and its dangerous goods emergency response plan in a report on the derailment.
Just days later, a train derailed along the Cheakamus River near Squamish, B.C., spilling caustic soda into the river, killing hundreds of thousands of fish. Again, the board blamed violations of the safety management system.
CN's policies were also cited as a factor in a fiery wreck in August 2007 in Prince George, B.C., and in a January 2007 derailment in Montmagny, Que., when four cars containing sulphuric acid derailed, but didn't spill.
A review of the industry's safety management policy released in 2008 concluded that the implementation of the policy had been inconsistent across the country and said Transport Canada hadn't dedicated enough resources to oversee it.
Federal auditor general Sheila Fraser also warned the government in a 2008 report that Transport Canada's transition to aviation safety management systems "had several weaknesses."
Fraser said the department didn't forecast expected costs for the transition, document potential risks or suggest mitigating actions and had no plan in place to evaluate the impact. She also warned there was no strategy in place to hire specialized people with skills gained on the job.
As a result of the recommendations in the rail safety review, McNulty said Transport Canada would be hiring 20 more inspectors for rail over the next three years.
While there are only a few dozen rail companies operating in Canada, there are more than 2,300 air operators certified to fly here.
Emilie Therien, past president of the Canada Safety Council, said the safety change in the airline industry will make Transport Canada a "toothless tiger" when it comes to enforcing safety.
"The safety level established by the carrier - whether it's rail or air - may not be the same one that was established by Transport Canada before," he said in an interview.
Hugh Danford, a former civil aviation inspector for the department, agreed, saying aviation travel is about profit and there's always a balance between money and safety.
"And that's why the (safety management system) won't work because they're putting that balance in the hands of the people who profit."
Copyright © 2009 The Canadian Press. All rights reserved.
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Risk, choice, de-regulation, "moral hazard"
The concept of SMS in our industry might be similar to de-regulation in credit markets, Financial, Banking, Enron, &ct. This offers any "operator" a free choice, to their own acceptable level of RISK. The concept of "moral hazard" might work for a while in the air transport industry.
Here's the same idea, or choice, expressed in 1930:
_NY Times_, August 1930
Here's the same idea, or choice, expressed in 1930:
_NY Times_, August 1930
“...Like System in Merchant Marine ...”
"... in anticipation that American enterprise will make aviation grow to tremendous proportions throughout the world with as much care in reducing hazard as was shown by the founders of the great marine transport lines....
"... Horatio Barber sponsored a policy of ‘moral suasion’ to exhort pilots and airline operators to greater efforts in safety and regulation ...
“... Barber held that two principal methods were possible for the reduction of the number of air accidents:
"... in anticipation that American enterprise will make aviation grow to tremendous proportions throughout the world with as much care in reducing hazard as was shown by the founders of the great marine transport lines....
"... Horatio Barber sponsored a policy of ‘moral suasion’ to exhort pilots and airline operators to greater efforts in safety and regulation ...
“... Barber held that two principal methods were possible for the reduction of the number of air accidents:
-- close bureaucratic supervision or
-- a practical and effective campaign to provide efficient and responsible direction among pilots and operators themselves.
"The last named method, he maintained, was as practical as the former and had the additional advantage of being cheaper and less restrictive to the growth of flying....-- a practical and effective campaign to provide efficient and responsible direction among pilots and operators themselves.
Will SMS improve aviation safety?
Safety is a relative concept – the absence (reduction) of risk. Aviation is very safe in comparison with other industries.
A view of SMS by James Reason Human Factors Aspects of Safety Management Systems might suggest that SMS may not result in greater safety, just a different view of safety; one which the industry/rgulators require at this time. However, in this he recognizes that not every operator is the same or will benefit from the same program.
If aviation is an “ultra complex and ultra safe” industry (Amalberti), it may well require the form of safety management envisaged by ICAO, perhaps better still as illustrated by Woods Creating Foresight.
The organizational changes required by SMS ultimately involve change in the way humans think and behave; in this instance at managerial level. The industry has attempted this at operator level through CRM with questionable success, thus can any more be expected from SMS; I doubt it.
On the positive side humans enjoy change, they focus on new and shiny concepts, thus SMS may reinvigorate tired and flagging safety programs, but for how long. How long in comparison to creating the anticipated universal change, we don’t know until we try.
Safety is a relative concept – the absence (reduction) of risk. Aviation is very safe in comparison with other industries.
A view of SMS by James Reason Human Factors Aspects of Safety Management Systems might suggest that SMS may not result in greater safety, just a different view of safety; one which the industry/rgulators require at this time. However, in this he recognizes that not every operator is the same or will benefit from the same program.
If aviation is an “ultra complex and ultra safe” industry (Amalberti), it may well require the form of safety management envisaged by ICAO, perhaps better still as illustrated by Woods Creating Foresight.
The organizational changes required by SMS ultimately involve change in the way humans think and behave; in this instance at managerial level. The industry has attempted this at operator level through CRM with questionable success, thus can any more be expected from SMS; I doubt it.
On the positive side humans enjoy change, they focus on new and shiny concepts, thus SMS may reinvigorate tired and flagging safety programs, but for how long. How long in comparison to creating the anticipated universal change, we don’t know until we try.
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The key issue is regulation and enforcement which requires comprehensive audit. SMS is a good tool provided there is no reduction in the audit process. This is where it becomes a worry as audit costs money and no audit saves money.
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SMS
SMS is outcome based legislation. Due to the complexities within aviation which includes regulatory and legal requirements, SMS needs to be paired with Compliance to a degree. Thrown into the equation is definitely a need for ongoing planned audits, in line with an SMS framework.
SMS has been mandated by ICAO, so its not going away, thats for certain !!
SMS has been mandated by ICAO, so its not going away, thats for certain !!
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Given that JAA/EASA is going the same way as Transport Canada (see the article below), self-regulation by the airlines is a great idea and will improve overall aviation safety. Discuss.
The public submissions on the notice of proposed rulemaking, docket FAA-2009-0671 Notice No.09-06 AC120-92 (Safety Management Systems), are all available at Regulations.gov. Quite a few submissions were received and you can read about how companies who have implemented/are implementing feel about SMS.
On October 13th, the Union of Canadian Transportation Employees (UCTE) made a submission suggesting "there is much the US can learn from the Canadian experience."
Included was an attachment, "Implementation of the Transport Canada Aviation Safety Management System (TCASMS): What's Not Right and Why Change is Necessary". Among other evidence, the document includes comparison of TCCA's approach to that of Australia, the UK and the US, as well as to what the ICAO directs.
It concludes:
The Aviation Safety Directorate of Transport Canada is leading the world in its approach and its implementation of Aviation Safety Management Systems. The question is; is it leading the world in the right direction or the wrong direction? Is it leading aviation safety in Canada down the wrong path and to a place where the travelling public may be at risk?
The conclusions in this report are that the TCASMS goes significantly beyond the framework and recommendations of ICAO. The conclusions reached in this report are that no jurisdiction in the world appears to be copying Canada - in its application of SMS delegations to trade associations and in its roll-back of direct inspections and audits. With the ever-developing ethos of increasing regulatory oversight and re-regulation, in the public interest, one has to question whether TCASMS is completely out of synch and needs to be reined in by Canadian political decision-makers. Perhaps this needs to happen very quickly before serious accidents occur.
UCTE believes that Transport Canada needs to engage stakeholders on these issues now. UCTE believes that a consensus for change should be something that Transport Canada strives for and achieves. For its part, UCTE is recommending the following changes in TC Aviation Safety today:
The conclusions in this report are that the TCASMS goes significantly beyond the framework and recommendations of ICAO. The conclusions reached in this report are that no jurisdiction in the world appears to be copying Canada - in its application of SMS delegations to trade associations and in its roll-back of direct inspections and audits. With the ever-developing ethos of increasing regulatory oversight and re-regulation, in the public interest, one has to question whether TCASMS is completely out of synch and needs to be reined in by Canadian political decision-makers. Perhaps this needs to happen very quickly before serious accidents occur.
UCTE believes that Transport Canada needs to engage stakeholders on these issues now. UCTE believes that a consensus for change should be something that Transport Canada strives for and achieves. For its part, UCTE is recommending the following changes in TC Aviation Safety today:
• It is wrong for TC to view aviation safety as an area to save money and cut jobs. This is a core area of federal responsibility and it is in the public interest to invest in air transportation safety. There are over 130 inspector vacancies in the Aviation Safety and Security Branch. These positions should be filled immediately. An additional 50 new inspector positions should be created. Transport Canada should also change the classification and pay structure to ensure inspectors are paid fairly and that wage inequities are eliminated.
• There must be a clear and unambiguous policy of direct and unscheduled inspections and audits for all Canadian air carriers - whether SMS certified or not. Effective risk management principles would clearly suggest that non-SMS certified carriers should be the subject of regular and random audits and inspections.
• There should be no delegations to associations.
• As recommended in the Aeronautics Act revisions suggested by the Parliamentary Committee on Transport, the Minister of Transport should, in a detailed way, define the "highest level of safety" and the Inspectorate should inspect to the standard generated by this definition.
• Transport Canada should clearly follow the U.S. Federal Aviation Administration lead in clearly articulating a detailed plan and commitment that defines its service and accountability to the public and not to the airlines. This includes complete whistleblower protections and safety accountability to agencies independent of the FAA.
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SMS
Hello all,
I will be taking a Graduate Certificate course from Embry Riddle on Safety Management which will include SMS.
I am asking those on this board who are in CAA country's to recommend various text's that would make up an appropriate reference library. SMS and overall safety systems management is an international phenomina, but most of the reference material I am aware of is published in the US.
I am looking for recommendations on other sources or text's with a more international outlook.
Thank you
Grendel
I will be taking a Graduate Certificate course from Embry Riddle on Safety Management which will include SMS.
I am asking those on this board who are in CAA country's to recommend various text's that would make up an appropriate reference library. SMS and overall safety systems management is an international phenomina, but most of the reference material I am aware of is published in the US.
I am looking for recommendations on other sources or text's with a more international outlook.
Thank you
Grendel
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Proof of SMS
Hello everyone, side bar question here:
I was asked today by a US operated VIP operation the following question: if the international community is mandating SMS, what documentation would a private organization need to carry to prove they have an SMS if they were to temporarily operate (flying the the VIP around) in a country that mandates it? What compounds the question is that the US is likely to be 2-3 years behind in establishing a framework for regulating the world of SMS implementation. Does anyone have any insights on what is planned for proof of SMS?
I was asked today by a US operated VIP operation the following question: if the international community is mandating SMS, what documentation would a private organization need to carry to prove they have an SMS if they were to temporarily operate (flying the the VIP around) in a country that mandates it? What compounds the question is that the US is likely to be 2-3 years behind in establishing a framework for regulating the world of SMS implementation. Does anyone have any insights on what is planned for proof of SMS?
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Proof of an SMS
Phrogman,
I think it's fair to say that the proof of an SMS would be ... an SMS. I'm not sure how you would go about demonstrating compliance in the foreign country without actually having a system in place.
The link to the UK CAA site in my previous post has some information that should be of use. Look at the 'gap analysis' link
I think it's fair to say that the proof of an SMS would be ... an SMS. I'm not sure how you would go about demonstrating compliance in the foreign country without actually having a system in place.
The link to the UK CAA site in my previous post has some information that should be of use. Look at the 'gap analysis' link
