Transport Committee on June 3rd, 2014

[Capt Scott Wilson]

I'll put a couple of points out there. We go through risk assessment when it is as simple as a change to an operating procedure to something as broad as taking on a new destination. There would be varying levels, obviously, of the complexity of the risk assessment that would have to be conducted.

[Jeff Watson, Conservative, Essex, ON]

How frequently are those mandated risk assessments being conducted, sort of, company by company? I imagine there would be some variability based on changes in operations too.

[Capt Scott Wilson]

They happen daily within the operational units for their change, and then it gets rolled up to be larger risk assessments at higher levels in the organization for broader changes.

[Jeff Watson, Conservative, Essex, ON]

Is every risk assessment mandated to be submitted with Transport Canada, or are there some that are simply internal?

[Capt Scott Wilson]

It's not submitted but it's all available under the normal oversight process.

[Jeff Watson, Conservative, Essex, ON]

Okay.

We're interested in recommendations for the committee. Obviously, we're going to be looking at whether there can be enhancements to the safety management system as well as the transportation of dangerous goods regime. That's what this committee is tasked with when we look at the aviation sector, not just rail, marine, or by truck.

You can give a brief answer now, but we'd appreciate something, if you would wish, in terms of follow-up in writing that would be a little more comprehensive than what you can provide at the table today. What recommendation would you make to this committee about how the safety management systems or the TDG regime could be enhanced?

[David Deveau]

I would just say to embrace the change with safety management systems and really to help clarify for the Canadian public some of the misinformation and mis-characterizations that are out there with respect to SMS, because it really speaks of the confidence the travelling public should have in what is the world's safest aviation environment.

[Jeff Watson, Conservative, Essex, ON]

Does anyone else want to handle that question?

[Samuel Elfassy]

I can answer that.

I would say, in terms of improvement, understand how important the data that we are collecting is and how that data is used. The benefit over the last many years, based on the systems that we're introducing, is to provide what I refer to as a high-definition picture of what is going on within an operation so that you can focus your efforts and your interventions on the system in the right place. That has fundamentally changed the way airlines operate. That data is important because it takes us to where the problems are.

I should say, though, on the risk assessment that I just want to make a point, which is that the importance of a risk assessment in all of our operations should not be underestimated. We conduct them—to a point that was made earlier—literally on a daily or weekly basis. There might be a small risk assessment to a more exhaustive risk assessment. In a high reliability industry like aviation, you do not want to introduce unintended consequences. That's why we take our risk assessments quite seriously, so that we can identify any of the residual risk that is left and try to mitigate that risk, because at the end of the day, you don't want to do any harm. Risk assessments play an important role in the safety oversight that the organization has.

[Jeff Watson, Conservative, Essex, ON]

This is sort of moving to one of the things that came up as a result of the Auditor General's report on the rail sector. You raised some concern about whether rail inspectors had any potential conflict of interest because they may have been employed previously in the rail sector before coming to the regulator. Is that a question of concern for the aviation sector? Is there any concern that there may be conflict of interest among Transport Canada aviation inspectors for the same reason?

[Marc-André O'Rourke]

No. To be perfectly honest, I don't know the background and experience of all the inspectors, but I can't imagine that this would be an issue. There are many air carriers, probably more air carriers than there are rail companies, but that would not be an issue.

Someone may want to jump in.

[David Deveau]

I would just add that our experience is that they are all very professional and that we would have no such concerns.

[The Chair, Conservative, Larry Miller]

Thank you very much.

Mr. Komarnicki is next, for five minutes.

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

Thank you.

One of the things we've heard from others is that when you have a safety management system, on paper it may look good, but there is the issue of actual implementation, as someone mentioned earlier, and there is a maturation process as time goes on.

Have you noted that in the airline industry? Can you comment on how you have seen it progress from paper to where it is today?

Mr. Deveau.

[David Deveau]

I think for all of the carriers here, our SMS programs have gone through numerous iterations through time—because we have some time under our belts here—and there definitely has been a maturing of the programs. In fact, we can much more often now see a direct link between outcomes—somebody mentioned injury rates, for example—and working back and being able to demonstrate that those happened because of the SMS itself.

That's a key point here, because this is what Transport Canada does in their oversight role. They want to see the link. They want to see how the processes you have in place have actually had a causal effect on some sort of worthwhile outcome.

With Jazz, we have been able to demonstrate that perhaps it was a result of a risk assessment and something we did there, or the result of a communication campaign.

That's a sign of the maturity: when you can start to show that the system is what made the change.

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

Mr. Elfassy, do you have a comment?

[Samuel Elfassy]

I would simply say that it's a very good point. One thing we have communicated over the last few years, based on surveys we have conducted of our employees, is that safety is not delivered by paper. It is not delivered by rules and regulations. It is delivered by people, because people deliver safety, and they're responsible for it.

It's putting a face on it, and putting a clear understanding of the rules and the expectations in all the airline employees. Whether they be a customer service agent, a flight attendant, a mechanic, what is their role in the system, and how do they contribute to the system so as to ensure that we are managing our efforts to be as safe as we can? It's removing the complexities. It's removing the barriers that often are challenging in understanding what your role is.

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

I also have heard that involving the employees or getting them engaged is sometimes—

[Samuel Elfassy]

That's critical. The communication process and the awareness is critical in the success or the failure of a safety management system. Everyone needs to understand their role. I agree.

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

Of course there is concern that there might or might not be retribution if an employee brings an issue forward. Do you have internally either training sessions or seminars or involvement of employees to go over what safety management systems are, what they are not, what they're meant to do, and to get a comfort level among the employees so that they become fully engaged rather than look at it from a distance?

[David Deveau]

Perhaps I could mention three things.

The first is that very much every employee has training with respect to SMS, on the expectations, the main policies, but we also gauge and measure whether or not employees believe that. One way is through the reporting rates. The reporting rates from front-line employees have exploded throughout the implementation of SMS, which tells you something initially, that they are comfortable enough to come forward and report. Incidentally, we have only a minute percentage of reports anonymously submitted.

Another thing, as someone else mentioned, we also do annual surveys which ask questions about their trust of the system, a non-punitive system. We get very high marks from employees indicating that they understand how it works and they trust it.

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

Have you any definitive report that says you have made an assessment of how your safety management systems are working and as of today here's how you have assessed it?

[David Deveau]

Do you mean internally?

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

Yes.

[David Deveau]

We have our own internal audit program, so we evaluate ourselves the components of SMS. As an IOSA airline, we also have external views on our SMS, and of course, there is Transport Canada oversight. We have many sources that validate the claim that the program is effective and evolving.