Transport committee  Yes. I'm also not sure the qualifications required of candidates are currently available. There has to have a lot of knowledge on safety management systems and risk management. However, pilots from outside the organization generally haven't worked—

Transport committee  I understand the concept of wanting everyone to input into the system and to have everybody's participation. There ought to be no punitive action brought against an individual when it's not done on purpose. We understand that. But what I'm saying is that in all of what we've seen thus far, there has been no enforcement action whatsoever conducted, whether it be premeditated or not, whether the action of the individual has been premeditated or not.

Transport committee  In fact, we're not looking; that's the difficulty. So we may as well be blind, because if we're not looking at what's going on in the industry, the result can be somewhat significant.

Transport committee  Transport Canada still maintains that they can enforce and they can apply punitive measures. It's still a tool that they say is available to them, but they're not using it.

Transport committee  My members have been reporting to me that in some areas they're now being told that they're not going to look at the 703 and 704 operators the same way they did before, mainly because they're so short-staffed and everything is focused towards implementing SMS at airports. This is the stepping away that we're noticing now.

Transport committee  Thank you, Mr. Chair. Good morning. My name is Daniel Slunder. I'm the national chair of the Canadian Federal Pilots Association. I'm here to provide you with an update on the status of SMS from the perspective of licensed pilot inspectorate professionals, who once conducted inspections, audits, and enforcement actions, but who now do mostly paperwork involved with SMS assessment in program validations.

Transport committee  I'm concerned, in that respect, that once you start taking boardroom decisions and financial considerations into the cockpit, you're going to get improper decisions that are not based on safety anymore. If you're starting to pressure the individual about the fact that if you're stuck in this place it's going to be $20,000 worth of additional fees for the overnight passengers, then it becomes a little difficult, especially when the individual knows that the bottom line of the company is pretty tight.

Transport committee  There's a lot to be said for someone on the ground when he's talking to his boss and saying that Transport could come any time here and we'll be caught. But if we're not there anymore to look, then there's no more safety belt for that individual. There is no fallback for that person.

Transport committee  In the past, our inspectors travelled on site and did pilot assessments. They assessed the training given to pilots and verified that the number of hours on duty did not exceed the accepted standard. They verified the carriers' certification. When a problem was noted during a site visit, it was discussed with the pilots.

Transport committee  I'm not sure I understood your question.

Transport committee  As Mr. Grégoire told you, they listened to our concerns. We met with Mr. Eley for two hours and provided him with 14 pages of information on SMS and roll-out problems. We had observed the problems that were occurring. However, the big airlines are encountering the same problems as the small carriers.

Transport committee  Personally, I just wanted to bring examples of where SMS is not working for us and why we don't have faith in SMS, the way it's being presented to us as a replacement for the types of inspections and audits we've conducted in the past.

Transport committee  Good afternoon, and thank you for the invitation to address you. My name is Daniel Slunder and I'm the national chair of the Canadian Federal Pilots Association. The association represents licensed pilots who are civil aviation inspectors at Transport Canada, the Transportation Safety Board, and Nav Canada.

Transport committee  All right. I regret to inform you that TC aviation inspectors now spend more time pushing paper than inspecting airplanes. With the introduction of aviation SMS, Transport Canada has systematically dismantled the key components of its prudent surveillance program in contravention of ICAO requirements to evaluate and inspect an operator's procedures and practices at least once a year, augmented by periodic random inspections.