Good morning, Mr. Chairman and members of the committee.
My name is Dan Adamus. I'm the president of the Canada board of the Air Line Pilots Association, International, and I'm a pilot with Jazz Aviation.
With me this morning is First Officer Mark Rogers. He is the director of the dangerous goods program with ALPA and is chairman of the dangerous goods committee for the International Federation of Air Line Pilots' Associations, IFALPA. First Officer Rogers is a pilot with United Airlines.
I'll share our views on safety management systems, and First Officer Rogers will address our concerns regarding the transportation of dangerous goods.
The Air Line Pilots Association, International represents more than 51,000 professional pilots who fly for 32 airlines in Canada and the United States. ALPA is also the largest non-governmental aviation safety and security organization in the world. As well as being our members' certified bargaining agent, we are also their representative in all areas affecting their safety and professional well-being. ALPA, therefore, has a significant interest in all issues affecting aviation.
ALPA supports the effective implementation of safety management systems in aviation. ALPA has embraced SMS as the next great leap forward in advancing aviation safety. We see it as a comprehensive corporate approach to safety that involves both management and employees. But here I must share a cautionary note: ALPA supports the “effective” implementation of an SMS. Now that SMS has been implemented for airline operations, our experience shows that a company may become technically compliant but not embrace the underlying concepts. Such an SMS is not an effective SMS.
ALPA strongly supports SMS for many reasons: it clearly establishes accountability for safety at the highest levels within a company; it provides for the reporting of safety occurrences and information without fear of retribution; and it requires employee involvement and a formal risk assessment and decision-making process. Under SMS a company is not able to ignore a safety issue by saying that it is regulatory-compliant. If a safety hazard is known or has been identified, a company is required to do a risk assessment and make a conscious decision on what mitigations are required to deal with it.
SMS clearly establishes responsibility for identifying safety risk where it belongs: with the aviation industry. The traditional method of safety oversight based on detailed technical inspections may appear to take on the role of operational safety assurance. That may allow the aviation industry to lapse into thinking and believing that safety is solely the government's responsibility.
We believe the following provisions are absolutely essential to the success of a company's SMS. To proactively address safety issues, data is required. Strategies to enhance safety need to be data-driven. In the absence of accidents, the right kind of data is required. Human and organizational factors create errors or hazards that remain largely undetected until the right set of circumstances results in a serious incident or even an accident.
An organizational climate in which people feel free from negative consequences when reporting errors, deficiencies, and hazards is essential to obtaining all the data that is available, and, therefore, to be effective, a reporting program must provide confidentiality and immunity from discipline, except in cases of a wilful or deliberate act, gross negligence, or a criminal act.
It has been ALPA's experience that most companies initiating SMS have fully embraced the concepts, adopting a safety culture from top to bottom. Unfortunately, a few do not. We have heard expressions of concern regarding protections from punishment and of confidentiality in reporting. In some situations personnel who bring forth safety concerns or self-report incidents have still been subject to disciplinary action. The effect is that employees cease to self-report, which stifles the flow of data, thus defeating the very premise of the safety management system. In these instances, the company has an SMS on paper, but has failed to change its culture.
Even with an effective SMS, the minister is still responsible for providing comprehensive and effective oversight and for taking the appropriate measures when necessary. When it is apparent that a company does not fulfill its obligations under an SMS, we believe that traditional oversight rather than the SMS audit system should be utilized.
ALPA understands that Transport Canada has delayed the implementation of SMS for 703 and 704 operators, and is in agreement with the decision. It is a relatively simple matter to legislate the requirement for an SMS, but you cannot legislate the cultural change required for an effective SMS. Therefore, taking the extra time for education, encouragement, and mentoring of these operators will be beneficial in the long term, as ALPA believes a voluntary, confidential, and non-punitive reporting program is an essential element of an effective SMS.
I will now turn it over to Mark for the dangerous goods portion of our presentation.