Actually, last week I offered to give you a technical briefing, so with your agreement, I will proceed with the deck. You have in front of you a deck in both French and English, so I'll walk you through it.
I welcome the opportunity to provide you with the facts concerning the development of the regulatory proposal on flight attendant ratios.
I have with me today Mrs. Susan Greene, Transport Canada's leading safety expert on this issue. Mrs. Greene flew as a flight attendant for eight and a half years, during which time she also supervised and trained flight attendants. Mrs. Greene currently holds the position of chief, cabin safety standards; however, she also gained security experience following the events of September 11, 2001, when she was responsible for developing the revised security training requirements for crew members and guidance materials for passenger agents working at check-ins.
I don't think you need an introduction from me, since I was here on Thursday.
On page 2, you will find a summary of the current flight attendant requirements. Canadian Aviation Regulations require that there be one flight attendant for every 40 passengers. Regulations also include a provision under which certain eligible aircraft configured with only 50 passenger seats can operate with a limited number of flight attendants, namely on regional aircraft such as the ATR42 -300, the Dash 8-300 and the Canadair Regional Jet.
The International Civil Aviation Organization requires that all countries adopt regulations based on the number of passengers or the number of seats. ICAO does not recommend the ratio, as such, and allows member countries to make the appropriate determination. The one flight attendant for every 50 passenger seats ratio is currently used almost everywhere in the world.
As an example, you have on the slide some countries that use the one-to-fifty regime today, but just glancing at the regulations in other countries, one sees that Austria, Bermuda, Brazil, China, Chile, Estonia, Finland, France, Germany, Iceland, Jamaica, New Zealand, Norway, Poland, Singapore, Slovak Republic, South Africa, Sri Lanka, Sweden, Switzerland, United States, United Kingdom, etc., are some of the countries using the one-to-fifty regime today.
On slide 4, when an aircraft is originally designed, built, and certified to carry passengers, a maximum permissible number of seats is established for the aircraft, based on numerous safety-related criteria, among which are the number and size of exits from the aircraft, the distance between the exits, and the aisle widths. Each crew and passenger must have emergency means to allow rapid evacuation in crash landings. The manufacturer of the aircraft must prove through actual demonstrations that a full aircraft can be successfully evacuated within 90 seconds in darkened conditions with 50% of the emergency exits blocked.
The common standard used worldwide for this certification requirement is primarily based on one flight attendant for every 50 passenger seats. So even in Canada, for the aircraft that we certify, we use the one-in-fifty rule. So do the United States, France, and Brazil, countries in which a lot of aircraft are manufactured. Slide 5 is about the risk assessment. As I mentioned last week, the first industry proposal was rejected in March 2001, as the information provided failed to demonstrate a level of safety in keeping with the existing rule. As there were, and still remain, polarized views on this issue, and with the broader scope the second proposal provided, Transport Canada decided that a formal risk assessment should be conducted. Stakeholders from industry, unions, and passenger safety and consumer groups participated in the risk assessment, and in September 2003 they were provided with the risk assessment report. The ability to manage risk in a consistent and effective manner is essential to making prudent safety-related decisions. Therefore, a strong risk management process is an important part of the department's effective service delivery in safety monitoring. While we cannot remove the risk completely, we can use proven techniques to ensure that all aspects of the risk are identified and considered when making decisions.
The Canadian Standards Association's Q850 process is the basis for Transport Canada's approach. This proven process provides a guideline that assists decision-makers in identifying, analyzing, evaluating, and controlling all types of risk, including risks to safety and health. This is the formal assessment that was used. I should add that most of our staff in civil aviation have been trained to use this process.
On page 6, there is a brief explanation of the proposal. Based on the recommendations from the risk assessment and comments from stakeholders, Transport Canada has developed a regulatory proposal in order to provide an alternative, along with additional mitigating factors, which will offer the same level of safety to Canadians. It is important to note that the proposal is a minimal requirement and that airlines will be allowed to select a higher number of flight attendants, as is often the case currently, for client service purposes.
Under the proposed regime, airlines which choose the 1:50 passenger seat ratio would be required to meet specific conditions that do not currently exist in the regulations. These additional requirements have been included to ensure that the proposed 1:50 ratio offers the same level of security as the current 1:40 ratio.
I won't get into the technical details of the mitigating factors we would implement but we will answer any questions you may have. However, I would like to point out that three new items are proposed to require airlines to demonstrate that they have the same evacuation procedures in case of an emergency, in order to assess the procedures and the airline's emergency training program as well as the crew members' skills and the capability of the emergency equipment onboard.
As shown on page 8, additional amendments are proposed to four existing sections of the regulations. I would like to draw your attention in particular to numbers three and four. Flight attendants would be limited to working on three aircraft types. As there are no limitations on the one-to-forty rule, that would remain the same. For large aircraft with two aisles, we would require at least one flight attendant per floor-level exit.
There are other considerations: first, passengers with disabilities, on page 9.
Canadian Aviation Regulations already require airlines to implement procedures for special-needs passengers, like visually impaired, hearing impaired or mobility impaired persons or unaccompanied minors. These procedures include a preflight briefing, as well as a briefing on emergency and evacuation procedures. An able-bodied person is designated to help every special needs passenger in case of an emergency or an evacuation. Flight attendants must provide an individual briefing to special-needs passengers and any able-bodied passenger accompanying them to explain emergency or evacuation procedures.
Transport Canada is confident that with the current additional regulatory requirements, aimed at ensuring inflight safety, the proposed regulations will contribute to maintaining passenger safety, including for passengers who have special needs.
Moving on to page 10, there are security considerations.
Moreover, these safety requirements are designed to prevent persons or objects that could pose a threat to inflight safety from coming on board an aircraft or having access to restricted areas in an airport. The overall objective is to avoid this type of situation by improving controls and better assessing threats to safety before they reach the aircraft. No scenarios regarding security issues were developed during the risk assessment portion of the safety assessment analysis since risks involving loss of life from terrorist or hijacking activity remain high regardless of the number of flight attendants onboard. The change in the number of flight attendants has no impact on safety issues raised during the consultation process.
On page 11, in choosing an option, it's important to know that air operators would be required to determine, on a company-wide basis--and I insist on that, as I believe I mentioned last week, it would be on a company-wide basis--whether it's to their advantage to stay with the current one-to-forty passengers or whether to move to the proposed one-to-fifty passengers. For each company, this will be a matter of examining their fleet composition, with the number of seats installed on each airplane, the number of floor-level exits on each wide-bodied airplane, and the projected load factor as critical parameters.
At the back of your deck I have included a chart that shows the impact of the one-to-forty and one-to-fifty regime for each operator and each aircraft in Canada.
On average, Canadian air carriers operate at an 80% load factor. In almost all cases, at 80% or below, there is no impact. As you will see by glancing through the table, the data indicates that the majority of aircraft would operate with the same or a higher number of flight attendants. At 90% and 100%, which is quite rare, there are some reductions for some types of aircraft. In most instances, there would be no difference in the number of flight attendants.
To illustrate this, I have picked three aircraft, which were referred to before, that are commonly used in Canada. Slide 12 shows the differences between the one-to-forty and the one-to-fifty ratios, based on various load factors of an Airbus 320, a common aircraft type used by Air Canada. Using the Air Canada configuration of 159 seats, with an 80% load of passengers, there is no difference in the number of flight attendants required under both scenarios.
On page 13 we show a scenario of a Boeing 737-700, again, with various passenger load factors. Under both the one-to-forty and one-to-fifty regimes, WestJet would be required to carry the same number of flight attendants: three, when there is a load factor of 80%. However, at full capacity, the one-to-fifty rule would mean one less flight attendant than the one-to-forty regime.
As you can see on page 14, on wide-body aircraft like the Airbus 340-300, the 1:50 seat ratio requires that there be more flight attendants in almost all instances, except if the flight is full. In this case, and only in this case, the regulatory requirement of the 1:50 ratio would be the same as the 1:40, it would require eight flight attendants onboard. For any other passenger configuration, there would be more flight attendants under the 1:50 ratio.
In closing, I would say that the proposed change was developed through broad consultation, in-depth analysis and expert studies that demonstrated that the different options will have no impact on safety. During the development stage, we consulted industry representatives, unions, consumer groups and passenger safety groups. And these people were also part of the risk assessment. The stakeholders will also have an opportunity to express their views on the regulations when they are published in the Canada Gazette, part I.
A majority of countries require one flight attendant for every 50 passenger seats. These aircraft often take off or land in Canada and Canadians often travel onboard these foreign-owned aircraft in which the 1:50 ratio applies. The regulatory changes would harmonize our regulations with those of most other countries.
I would like to add that in this day and age, airlines have code share partnerships with other airlines. For all practical purposes, that means that if you have traveled abroad, even with a Canadian airline ticket, it's very likely that you have traveled onboard a plane where the 1:50 ratio applied. We are convinced that you did so safely. The same can be said of domestic flights. In the case of the Regional Jet or the Dash 8-300, the ratio is currently 1:50. We have never heard complaints of any kind regarding this.
Consultation is part of the development of all our Canadian aviation regulations, and our formal mechanism for initial consultation is the Canadian Aviation Regulation Advisory Council, commonly called CARAC. CARAC has participation from a large number of organizations outside Transport Canada representing the overall viewpoints of the aviation community.
I can assure you that throughout the regulatory process, whether at CARAC or during the gazetting process, all comments are carefully reviewed and play an important challenge function in ensuring that the department's decision is sound and can withstand scrutiny.
That means that when the time comes to decide to move forward with a regulatory proposal, the risk assessment has taken place and the department feels that this decision is in the best interest of Canadians.
Transport Canada will not introduce a change that could be detrimental to Canada's excellent reputation on safety. We take our role very seriously. The proposed regulatory changes demonstrate that we are determined to maintain a profitable civil aviation network without compromising its safety.
Thank you.