Thank you, Chair.
Honourable members, my name is Norman Chalmers. I'm the president of Pacific Airworthiness Consulting.
I have 47 years of experience in the business of aviation safety and aircraft airworthiness, including 25 years in Transport Canada Civil Aviation in various positions, including periods as acting regional manager. Besides consulting, I write a bimonthly column for Air Maintenance Update Magazine, which is widely read in Canada and the United States.
Today I limit my comments to safety aviation management systems, SMS, as implemented by Transport Canada Civil Aviation.
On my position regarding SMS, first, SMS is a social engineering experiment on a huge scale, with the Canadian aviation industry safety outcomes as the study objective and the travelling public as the victims. Long-term consequences of these changes are unpredictable, because Transport Canada SMS has no precedent or proven models.
Second, SMS is a good idea, essentially the same as total quality management. Safety management systems, if properly embraced by management and workers, can help companies improve themselves in many areas.
Third, SMS is not a regulatory regime. It's essentially a philosophy invented by reductionist university professors who have studied and dissected disasters in the petrochemical industry. These experts include Reason and Hopkins.
Fourth, SMS can not successfully replace regulatory oversight.
Fifth, SMS is a Transport Canada tactic to save money on employee costs, including numbers and qualifications.
Sixth, SMS is a Transport Canada tactic to avoid being sued in court for allowing unsafe aviation operations.
Seventh, SMS was sold to Canadians, yourselves included, using scare tactics, including using the widely distributed worldwide hull loss projections.
Eighth, the lawmakers of Canada have been negligent. They have ignored the warnings of Canada's best people, including Mr. Moshansky in this committee's 2007 meetings and report.
Ninth, Canada has one of the safest transportation systems in the world as a result of the corporate safety culture of companies and the people working in the industry. It is also a result of the effective regulatory requirements.
Tenth, Transport Canada has started to dismantle those requirements.
Eleventh, SMS implementation by Transport Canada will do long-term and enduring damage to aviation safety in Canada.
Twelfth, it will soon be too late to prevent that damage. Canada will face a very difficult time rebuilding the safety infrastructure that is now being destroyed.
Thirteenth, public opinion regarding “safe aviation” and “safety” do not coincide with Transport Canada's definition and are not supported by Transport Canada's actions.
Those are my positions.
On SMS and PVI implementation, SMS is not an “additional layer”, as it was sold to your 2008 House of Commons committee. It was never planned as an additional layer. At the same time as those individuals were telling the Commons committee that SMS was an additional layer, they were telling us inspectors to stop doing audits. Transport Canada leaders were not truthful.
SMS assessments and program validation inspections have almost totally replaced audits and inspections. I know of no regulatory audits in the last five years. The Aeronautics Act regarding SMS does not address all aspects of SMS as implemented, and the act embeds a vague level of safety.
The CAR 107—when I say CAR, I mean Canadian aviation regulation 107—regarding SMS is vague and nebulous, at barely 300 words. This CAR leaves the requirements in the hands and subject to the whims of the bureaucrats at all levels, from senior mandarins to inspectors, and it encourages bullying.
Transport Canada Staff Instruction SUR-001, revision 5, is the primary SMS compliance document. At about 33,000 words, it defines and implements the intent of the act. It is a third- and fourth-level document. To understand SMS, you must become conversant with SUR-001, with which the vast majority of the aviation community is not familiar.
Other areas of Transport Canada infrastructure have been left without support. No credible organization supports the current directions of Transport Canada. PVIs have totally replaced audits on non-CAR 705 SMS companies or organizations. SMS was implemented without any risk assessment or human resources planning. SMS was designed and pushed into place by people with no experience in the civil aviation industry. There was no formal or recorded public consultation. The program bypassed the CARAC process of public consultation despite Transport Canada assurance regarding CARAC involvement. The training for inspectors was and is poor.
SMS is implemented but has little effect on the SMS companies under CAR 705. SMS is implemented for the rest of the non-CAR 705 industry. The implementation has stalled or died.
There is decaying regulatory infrastructure. Having Transport Canada policy-makers and Ottawa staff's total focus on SMS has left other areas of aviation regulation to decay. Implementation and administration of SMS have been taking up almost all the time and effort of the whole staff of Transport Canada.
The Transportation Safety Board of Canada aviation watch-list contains 85 open safety recommendations, some with Transport Canada responses found unsatisfactory. There are regulations and standards that have been technically wrong for years.
The results of Transport Canada Civil Aviation's overall attitudes and actions can be easily found in the reactions of the public safety experts. You will find further evidence in the public service employee survey organizational results. The number of working days lost due to employee absence on medical grounds should be examined, with emphasis on stress leave, in line with the cases I know about.
Long-term results on aviation safety for Transport Canada's new approach, including reliance on SMS, will only be evident in the long term when Canada's aviation safety record changes in relation to the rest of the technologically developed world, which currently shows improvements in safety. If the government is truly interested in aviation safety in Canada and in the effects of SMS implementation, it ought to conduct opinion surveys of Transport Canada's own inspectors and the Canadian aviation industry.
That's it for me. I think I beat the 10-minute deadline.