Good morning.
We thank the committee for giving us the opportunity today to express our concerns about aviation security. The AQTA is a non-profit organization which works to further the development of the air transport industry in Quebec. We represent the following sectors of the industry: carriers—airplanes and helicopters— airports, maintenance and certification companies, piloting schools and service enterprises.
The purpose of Security Management Systems is to increase the level of security by putting in place a corporate culture based on security within the industry, which is already a very safe industry. The concept of Security Management Systems, SMS, has never been presented to carriers as a self-regulation mechanism. It was, rather, presented in the very beginning as an alternate solution to operational verification activities. I remember well the first presentation on the topic in Montreal in the offices of Transport Canada. The carriers were surprised by the news. Later, the approach changed and currently the SMS is no longer an alternative concept but an complementary one for the operators.
The AQTA is now in favour of SMS in the industry. However, we believe there are major problems to be overcome in the implementation of this concept with small operators and piloting schools.
The delegation of responsibility regarding security to the senior manager does not confer instant competence in the area of SMS. That is why we need training tools to implant this system.
As for resources, we have some serious concerns. On the one hand, although airlines have limited resources, they have a superior capacity to that of small organizations to put in place such a system.
Since the SMS was put in place by the large carriers, we noted a substantial increase in the workload of Transport Canada inspectors. They have run out of time to carry out their inspection activities and this fact was recognized before the committee. The workload for the next phase is, we feel, even greater. The 705-type carriers are proportionally speaking not very numerous in the country as compared to other types of operators.
Recently, in March 2010, an organization known as the CAMAQ did a survey and found that there were 158 businesses specialized in air transport and the maintenance of aircraft. Of that number, 105 had fewer than 10 employees, that is to say that to date, Transport Canada has not even grappled with two-thirds of the problem represented by the implementation of this system.
With regard to training, inspectors have already received training and more is projected. As for the carriers, only the documentation is offered on the Internet. Strangely, during program validation inspections, Transport Canada does not recognize the value of self-training on important topics. Since Transport Canada feels that the SMS is crucial to our security objectives, would it not be normal to at least have some training materials in order to be able to provide training in-house?
We indicated before the committee that Transport Canada was working in cooperation with the associations. That is what we do with Transport Canada. However, we deplore the lack of financial resources. We asked for financial assistance from Transport Canada to hold workshops and our request was denied.
Is it possible to apply the SMS concept to businesses of all sizes and is it really relevant to do so? We feel that the bigger the company, the greater the need to have a system that allows for contact and feedback from the frontlines. When a business only has 15 employees or less and when the owners are a part of that, is it really useful to put in place an SMS system? How can we use statistics on security when operations are seasonal or when the volume of activity is so low that trends can only be charted over several years? For instance, where airlines are concerned, an SMS report is generally generated for every 1,000 flight hours, whereas certain Quebec operators have fewer than 700 flight hours per year.
We are facing a considerable challenge. Transport Canada does not in our opinion have the resources allowing it to supervise the implementation of SMS by all of the small carriers and those operators do not have the capacity nor the necessary competence to put in place such a system.
In conclusion, before allowing Transport Canada to prepare training tools and conduct orderly supervision over medium-sized carriers, we suggest that SMS regulations apply to businesses that have more than 15 employees. When this phase is over, it will be possible then to move on to the smaller businesses. These businesses only represent a small percentage of activity in Canada.
Transport Canada authorities told you that they would not accept any compromise insofar as security is concerned. Our proposal to restrict the application is not one that will compromise security but rather a pragmatic measure to ensure that the next implementation phase of the SMS will not once again interfere with inspection activities.
In this way, we will safeguard our reputation in the area of security.
Thank you.