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Lost Promise of SMS

The cornerstone of SMS is recognizing and mitigating your own risks before they become accidents. In short, the operational community takes more responsibility for its own safety.

In the past few years at HAC, I have witnessed a flurry of activity in the operational community as prudent operators erect the pillars of their SMS programs. I have witnessed operators implement HFDM, and HUMS, and Satellite Tracking Systems, and Voluntary and Non-Punitive Reporting Programs, to name only a few.

I have witnessed HAC committees developing Industry Best Practices, including Pilot Competencies for Helicopter Wildfire Operations, Best Practices for Onshore Oil & Gas Operations, and Best Practices for Utility Flight Operations. Our committees are developing Best Practices for Heli-Skiing and Mountain Flying and types of Class D Operations.

When the aviation community was introduced to SMS more than 10 years ago, Transport Canada promised that if operators accepted more responsibility for recognizing and mitigating their own risks, they would receive relief from the prescriptive regulations.

In fact, at the time, TC was actively soliciting the involvement of aviation stakeholders (airports, helicopter operators, business aircraft operators) to accept more responsibility for their own regulatory environment.

The Canadian Business Aviation Association (CBAA) was on the leading edge of this initiative with its POC Program, aptly referred to as “regulatory stewardship,” but other industry segments and associations flirted with the concept, including this one.

However, the announcement by the minister that the CBAA POC program would be repatriated to TC, signalled a sea change inside the department. The idea that prudent safety-conscious operators could receive relief from prescriptive rules has simply evaporated. There has been no further discussion with the aviation community about “regulatory stewardship” programs or even about further Delegations of Authority.

At the same time that TC was encouraging operators to accept more responsibility for their own safety with SMS, it was refusing to offer them more responsibility or recognize the ones that stepped up to the plate. Couple this with declining levels of service from TC, and most recently with the federal budget’s 10 per cent reduction in funding to TC, and the prospect of a more progressive form of regulatory oversight is bleak.

The exodus of experienced inspectors from the department certainly does not inspire confidence. The fact that the phased implementation for SMS in the CAR 702 and 703 segments of the industry is a constantly moving target does not bode well for Transport’s leadership and its ability to “close the deal.”

And as I noted in the Helicopters roundtable last year, the challenge with SMS is two dimensional. One dimension is that the smaller operators seem to be having the most difficulty implementing it because the system was designed for implementation in a larger operation. The promise of SMS has been its scalability for small operations, but it is more difficult in practice than it was in theory. The other dimension is that implementation date is constantly moving off.

Yes, there are significant issues within TC with culture and getting the culture change with inspectors, but it’s getting to a stage where the credibility of the process is being affected by the constantly moving implementation dates. And like many other things TC does, the systems are built for large operators and the small operators are an afterthought about how it’s actually going to work in a small operation.

The issues of poor service levels and a backlog of important issues – including the implementation of SMS – were raised again at this year’s roundtable (see, “Finding the Right Resources,” pg. 17).

My other greatest fear about SMS, raised originally by TC, was that it would simply amount to another layer of regulation on top of the prescriptive CARs and I currently see no reason to believe otherwise.

If SMS is to amount to more than this, then HAC challenges TC to articulate the benefits that will accrue from the regulator to prudent operators that manage and mitigate their own risks – to the operators that exceed the regulatory standards set out in the CARs. If industry develops best practices or its own audit standards, will TC recognize those operators that embrace them?

Fred Jones is the president/CEO of the Helicopter Association of Canada and a regular contributor to Helicopters magazine.