Transport Committee on June 3rd, 2014

[Ed Komarnicki, Conservative, Souris—Moose Mountain, SK]

Thank you.

Of course, you're indicating that SMS involves proactively managing the risk, not just following rules and regulations and so that dimension is added to it. I think it was you, Mr. O'Rourke, who said that you seek to find an unknown risk. When you have a risk, you know what it is and you can work to fix it, or if you have an incident you can work backwards. I'm curious if you can give me an example. How do you seek to find an unknown risk?

Then you said digging into specific areas of concern is another aspect of safety management. Perhaps you could give us some examples of that.

[Samuel Elfassy]

I think a really good example of trying to identify an unknown risk would be some of the proactive exercises that we conduct, and when I say we, I mean collectively conduct.

One example would be something referred to as LOSA. LOSA is a line operations safety audit. Essentially, what it involves is taking trained observers, generally pilots, putting them in the flight deck and observing various behaviours of the flight crew in order to determine how those individuals manage various threats, various situations on board the airplane. That's a proactive activity that sometimes will uncover threats to the organization, but also the resiliency of the organization, behaviours that you want to manage.

Part of the safety management system is taking all of these elements that I think David mentioned earlier, the LOSA, the audit, which are the proactive, the investigations, the reports that come from flight attendants, pilots, and maintenance organizations.... All of that goes in, in order to give you a lens about what is going on within the organizations—where those hazards are; where those risks are—and feeding them back through the organizations so that they can manage those risks and then monitoring for the effectiveness of those solutions. It's an iterative process.

That would be an example of one that you will uncover because you don't know about it. It needs to be a proactive exercise. You just don't wait for it to happen.

[The Chair, Conservative, Larry Miller]

Thank you.

Mr. Watson, for five minutes.

[Jeff Watson, Conservative, Essex, ON]

Thank you, Mr. Chair.

Other than WestJet on the one in 50 exemption, is there any other airline represented here that has a one in 50 exemption on flight attendants? Is it just WestJet?

[Samuel Elfassy]

Currently Air Canada does not have an exemption, no.

[Jeff Watson, Conservative, Essex, ON]

You've now had seven months in that operating environment. Has your company done any of its own surveillance as a follow-up to the implementation of the exemption, and what can you say based on that?

[Capt Scott Wilson]

A promise we made to the minister as part of incorporating the exemption was the fact that the safety management system required to provide that oversight is what we've had—surveillance activity with Transport Canada inspectors on board as well through the implementation. We take a look at the data.

One of the better things I'll point to and it's tied nicely with our requirements to the labour code as well, but two of the seven months have been the lowest months for flight attendant injuries ever in the history of WestJet. There are a lot of data that comes back when we talk with flight attendants on board. In fact, on the flight out here yesterday, I served with the flight attendants to have discussions ongoing and we get continued positive feedback on one in 50.

[Jeff Watson, Conservative, Essex, ON]

In your testimony just now you said that Transport Canada itself has been part of the post-implementation surveillance.

[Capt Scott Wilson]

We actually came out of one of the large assessment activities, so one in 50 was part of that oversight. It was a complete assessment that basically started back in November with the off-site activities, culminating in February. We also see in-flight cabin safety inspectors who travel on the airlines. They travel in the back and they observe activities, which they report back to the airline.

[Jeff Watson, Conservative, Essex, ON]

On your post-implementation surveillance, and I'm talking about WestJet now, presumably a report has been commissioned, or some sort of report was made about that. Can any of that be tabled in terms of the analysis with the committee?

[Capt Scott Wilson]

That's all ongoing. We use something similar to what Sam spoke to. We use the cabin operations safety audit, COSA. We have flight attendants, who are on board all the time, looking to see how flight attendants operate in the environment and ensure that all the procedures are being met and that there's been no reduction in safety margins.

[Jeff Watson, Conservative, Essex, ON]

Back to SMS in general for the airline industry, do each of your companies have a designated executive whose primary responsibility is safety operations? Are the duties and responsibilities of that particular executive very clearly defined?

I'm seeing heads nodding. I just want each of the companies to answer very briefly.

[David Deveau]

In Jazz's case that would be me, understanding of course that the accountable executive, which includes the responsibilities under safety, is the president and CEO.

[Jeff Watson, Conservative, Essex, ON]

Mr. Elfassy.

[Samuel Elfassy]

Our president and CEO is designated the accountable executive. You should know that in selecting an accountable executive, Transport Canada provides essentially a flow chart that determines whether or not that person can actually be nominated.

The ultimate decision-maker, based on the resources and the financing of the organization, rests with the president. They're ultimately responsible. They delegate the maintenance and the monitoring of our safety management system to me.

[Jeff Watson, Conservative, Essex, ON]

Mr. Wilson.

[Capt Scott Wilson]

It's sort of the same situation. Going through the flow chart, the president and chief executive officer is the one who is the accountable executive under the regulation for WestJet. Then, of course, certain duties and responsibilities are delegated out; however, the actual accountability cannot be delegated away.

[Jeff Watson, Conservative, Essex, ON]

Mr. Mignault.

[Capt Jacques Mignault]

It's exactly the same at Air Transat, with the CEO being the accountable executive. I am basically mandated by the chief of operations and chief of maintenance, who are ultimately responsible for the safety of their own operations. I'm there to assist them in managing the systems, so that they get the information and the follow-up to any incidents.

[Jeff Watson, Conservative, Essex, ON]

How do you overcome siloing? There are mandated components that comprise a safety management system. How do you overcome that to have a full systems approach to safety? How do you resist the tendency to sort of silo within a component?

[Capt Jacques Mignault]

Precisely in our system, there are no silos. Everything is intertwined. My safety team is integrated in all sectors. We work together for a single event. It may warrant investigation on various aspects, whether it's flight operations, cabin operations, maintenance.

Whatever is involved in a particular incident is collected within this investigation, so everything is very much interlinked and there are no silos at all.

[Capt Scott Wilson]

I would strongly suggest that if you look at the requirements for safety management systems, the ability to remove and break down silos is one of its greatest strengths. It looks for that and if you don't have that naturally occurring within your airline, Transport Canada will be there to ensure that with the expectations set out, you have committees, etc., with the ability to ensure that it's not operating in a siloed approach. It's meant to be very holistic throughout the organization.

[The Chair, Conservative, Larry Miller]

Mr. Watson, you're out of time.

We're going to go to Mr. Mai, but I'm going to be very strict on the time for everyone. Five minutes for the question and the answer.

[Hoang Mai, NDP, Brossard—La Prairie, QC]

Perfect. Thank you, Chair.

Just to answer Mr. Komarnicki's question with respect to the survey, it was done with inspectors, employees of Transport Canada, who actually enforce Canada's air safety regulations so when these people, 85% of them, say air travellers are exposed to higher risk....

Here we are as regulators trying to make sure the system in place is the safest one. I think we all agree, and I'm sure the airline industries also agree on that. That's why we have questions, especially when we saw what happened on rail safety. Obviously you have followed what happened in Lac-Mégantic. There were faults in the system. SMS is the same thing. We heard from railway companies saying it's the safest thing, but when we looked at it, we realized it was meant to be another layer. I think you all mentioned it. It was meant to be an additional protective layer, but what we've seen on the ground is that there are problems with respect to inspections.

I talked about the facts. There is the fact that we have fewer inspectors with Transport Canada to look at some of the issues. I don't necessarily agree that Transport Canada has done everything and even more than it's supposed to. Even the Auditor General has said that.

When we come back to SMS, for instance, and when we look at the change of ratio—we spoke about it today for flight attendant ratio—are flight attendants being involved in the SMS that would come after that? You say, yes, but when I was there and Mike Sullivan was there at CARAC, I don't think we heard any flight attendant say that would increase safety. That's my concern.

You say you're working with the employees, but then we hear about the employees not being satisfied and saying there is a higher risk. That's why we ask questions.

For instance for the reduced flight attendants ratio, how involved are the flight attendants in terms of...?

[Capt Scott Wilson]

Flight attendants at WestJet are involved very closely with any operational change. That's one of the tenets of a strong safety management system, that one of the components or the expectations is you have strong processes around the safe management of change. Change management is tough for everyone, inspectors and employees alike, within airlines and within transport.

When we looked at implementing one in 50, obviously the comfort came in the availability of data...to speak to flight attendants from around the world, and it suggested we cross the border. In the FAA jurisdiction or Europe, they operate under one in 50 exclusively and have so for years. I think they would be very much aligned with us. They don't see that necessarily is tied to safety, having a ratio of one in 40 versus one in 50. With our equivalency, we're quite comfortable with that from a safety perspective.

Any time we do organizational change at WestJet we use a lean process, something that is found in Japanese culture. Our employees are included in the change. Basically since they are the ones that do the front-line job, we ensure they are encouraged to have their voice heard on the procedures and processes they do on a day-to-day basis. As that is a starting point, we ensure they get that opportunity. Then of course once the process is identified, we're required to follow up from efficiency, through our close audits, etc., so we ensure their voices are heard. Then basically the processes are changed.

They have a great ownership on the front line of the safety and the process that they are involved with.