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.
At my last appearance before your committee, I presented the results stemming from the lack of traditional inspections and audits. The issues we identified occurred because inspectors had been forced to focus exclusively on SMS assessments and validations instead of audits and inspections. In short, aviation inspectors have not been watching the safety practices of the aviation industry as they once did. In our opinion, and in the view of many outside experts, the absence of traditional safety oversight represents a serious risk to the travelling public.
Following my last presentation to your committee, we met with Transport Canada officials. The department wants to work cooperatively to resolve some of the pressing safety issues we identified. We're encouraged by this turn of events, and cautiously optimistic, particularly given Minister Baird's recent decision to return business aviation to direct Transport Canada supervision. There are, nevertheless, formidable safety concerns that remain.
Aviation safety incidents reported through CADORS, the civil aviation daily occurrence reporting system, continue to increase every year. They have increased from a reported 4,000 incidents in 2000 to 14,000 incidents last year. This is troubling, as CADORS incidents are generally precursors to or indicators of a larger safety issue. Traditionally, many CADORS incidents were investigated, resulting in enforcement action, yet when we searched the records for the last two years, we find no record of any enforcement action against large operators. Let me repeat: there have been zero enforcement actions against large operators during the past two years.
Transport Canada has always insisted that SMS is an additional layer of safety over traditional oversight. In the interests of public safety, there is an urgent need to reinstate a traditional oversight program that has atrophied during the introduction of SMS.
Transport Canada officials made some encouraging announcements. They testified on March 30 that their goal is to assign 70% of the inspectors' time to SMS validation and 30% to the traditional type of inspections.
The principle behind this announcement is welcome, but the reality is far less encouraging. As you've already heard, the latest version of TC surveillance policy requires that 100% of SMS assessments and validations must be completed before inspectors are free to conduct traditional audits or inspections.
For inspectors, Transport Canada's number one priority right now is to roll out SMS at airports. Next will be the hundreds of small 703 and 704 operators. Today it is impossible to accomplish all SMS tasks; therefore, we will continue to turn a blind eye to safety concerns in aviation operations. Even though SMS assessments and validations are largely a paper exercise, they take an extraordinary amount of time.
CFPA members report that it used to take one week to conduct an audit of a typical operator. Under SMS, there is one week spent preparing for a validation; the site visit requires two or three days; and the validation report takes a week to produce. It easily requires twice as long to assess and validate a company's SMS. Meanwhile, inspectors are reporting to me that scheduled surveillances and inspections are being cancelled.
Before Transport devolved business aviation in 2005, there were five person-years assigned to monitor 150 certificate holders. Now, with business aviation under regulatory surveillance, inspectors will have, as you've heard, up to an additional 400 certificate holders to review and monitor.
Perhaps you've heard that Transport Canada is hiring inspectors. This is a step in the right direction, but it amounts to a band-aid gesture when major intervention is required to restore traditional oversight to the much-vaunted additional layer of safety for the travelling public.
Consider that the professional pilot inspectorate represented by the CFPA has reached near historic low levels. Approximately 100 positions are currently vacant. At the supervisory level, there are 40 vacancies. Like cascading dominoes, this has the effect of pulling working level inspectors away from their day-to-day responsibilities to backfill supervisory jobs for which they were not trained.
Transport Canada has hired 20 working level pilot inspectors in the last year, ending in February; during the same period, 27 inspectors left Transport Canada, for a net loss of seven front line pilot inspectors. This puts into proper context Transport Canada's plan to hire 100 additional inspectors, the majority of whom will not be professional pilots. Even after these new hires, it will be impossible for inspectors to complete their SMS assignments while devoting 30% of their time to traditional oversight activities.
In order to achieve the additional layer of safety concept, Transport Canada needs to restore the working pilot inspectors to the pre-SMS levels of approximately 500, then add 30% more inspectors, for a total of 650. This task will not be easy given the demographics of the professional pilot inspectorate at Transport Canada.
In 2008 the CFPA commissioned the well-known demographer, Dr. Linda Duxbury, to study the licensed pilot inspectorate. Professor Duxbury concluded that we face a crisis in aviation safety oversight, arising from an aging workforce. More than half of this workforce is eligible to retire starting next year, taking our most experienced professionals out of the picture. With no effective program to retain inspectors or recruit replacements, Duxbury said that we are heading for a “very high potential for a shortage, a huge and profound shortage”.
I have circulated a backgrounder to give you a sense of our conclusions. Transport Canada officials testified to your committee that they must shuffle internal departmental resources to make ends meet in the civil aviation directorate. TC seems to be doing the best it can with available resources, but it's not good enough. To protect the travelling public and achieve the much-touted additional layer of safety, which requires the restoration of traditional oversight, Transport Canada needs a significant infusion of resources. That decision rests with elected officials like you.
The absence of traditional oversight is not the only problem with Transport Canada's SMS. You will recall from my previous appearance that I told you about a troubling incident with an Air Canada flight. Due to a number of circumstances that piled up one on top of another, a number of serious violations of Transport Canada's safety regulations occurred, including refueling with engines running, which placed passengers at risk.
This incident became public only because an experienced pilot on board as a passenger reported it to me. In addition to the hot refuelling, he was concerned about the presence of ice on the wings. The concerned passenger/pilot reported this incident to Transport Canada and, under SMS, it was referred back to Air Canada to address. Even though serious infractions of the safety regulations occurred, no TC action was taken, and Air Canada has full responsibility to address the incident and no obligation to report their actions.
We'll never know what action Air Canada has taken to address this incident because TC's SMS provides airlines with immunity from enforcement action and complete confidentiality for self-reporting. This amounts to a veil of secrecy. So you and the public will never know.
To end on a positive note, I'm happy to report to you that Transport Canada has listened and recognized that SMS training for inspectors is an issue and must be addressed. There is a plan to introduce a revitalized course in September. Overall, senior management at Transport has improved communications with us and is attempting to address issues that were previously highlighted.
Thank you for giving me the time to present this.