Safety & Training
Standards & Regulations
Losing Its Focus
May 15, 2013 By Fred Jones
For the past five years or so, the committees at the Helicopter Association of Canada (HAC) have been producing best practices for our industry.
For the past five years or so, the committees at the Helicopter Association of Canada (HAC) have been producing best practices for our industry. A best practice represents a consensus of the industry on how a particular type of operation should be conducted. In short, “How is a prudent and reasonable operator conducting business in a particular operation type?” That doesn’t mean the very best operator – or thankfully, the very worst.
HAC’s committees are encouraged to engage with their customers when they develop best practices. We welcome them to engage with us. Our customers are becoming increasingly informed consumers of helicopter services, and it is part of their due diligence to ensure that their employees are protected from operators that are providing a service that may put them at risk. The evolving best practice among informed consumers of our services is to insist that their transportation providers exceed the regulatory requirements to standards established by the customer, and subject themselves to arms-length third-party audits.
The HAC Air Taxi Committee for example, has produced a Pilot Competencies for Helicopter Wildfire Operations Best Practices Training and Evaluation document. The document was driven by operator-concerns that the minimum fixed-hours required by customers was an imprecise measure of a pilot’s ability. Most of our customers agreed, and the result, HAC believes, is a less prescriptive, more precise mechanism for assessing the ability of the pilot to complete the required mission objective(s).
See: http://www.h-a-c.ca/PQWG-Pilot_Competencies_for_Helicopter_Wildfire_Operations.pd f.
From an operational safety perspective, the development of a best practice starts where the Canadian Aviation Regulations stop. That is, a best practice must meet, or exceed the regulatory requirements, or fill a gap that the regulations do not address at all. Even in a highly regulated, businesslike aviation environment such as hours, there are many areas that remain untouched, except in a very general way, by the long arm of the law. HAC best practice documents are filled with guidance on issues that the regulations cannot begin to address. Our best practice documents speak the language of safety management systems (SMS) and encourage operators to conduct risk assessments to evaluate the subtle but very real risks associated with a broad variety of the operational variables in their operations.
The reality is that the regulations and assessments of regulatory compliance are a blunt instrument for the purpose of determining whether an operator is managing risk in a reasonable fashion. They can only hope to catch the most obvious and flagrant violations of safety. Most of the time, the causes of accidents and incidents are far more subtle – buried in management practices, the company safety culture (or lack thereof) or the company’s disregard for the risk indicators that are the antecedents of an impending occurrence or fatal accident.
Now, admittedly Transport Canada (TC) has started looking at some of these things. The organization has been driving operators to accept more responsibility for managing their own risks, but TC is still only left with the traditional enforcement tools when it determines that the operator’s SMS has “broken down” or the company has “lost operational control.”
To make a bad situation worse, TC has been quick to extend considerably more responsibility (and cost) to the operational community without also extending any more authority or freedom.
There are so many examples of successful delegation in our industry, and so many operators that are trying to “do it right,” that it just makes no sense to HAC that TC is so reluctant to extend more authority to responsible individuals and companies. Why not start by extending it to operators who have taken the time to develop and implement a working SMS and who can prove that they have operationalized industry best practices?
It’s becoming painfully clear that the regulator can no longer live up to its mandate to regulate our industry in a meaningful way. It is increasingly out of touch with industry operational procedures and best practices and has little time for the industry issues that are truly meaningful to helicopter operators in Canada – those that will enhance safety and efficiency. Instead, the regulator appears to be decidedly preoccupied with “reorganization,” budget cutbacks, and a lengthy and largely unproductive preoccupation of the airline unions with flight and duty time working group recommendations that have little relevance to the helicopter community in Canada.
Fred Jones is the president/CEO of the Helicopter Association of Canada and a regular contributor to Helicopters magazine.
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