Good morning, ladies and gentlemen.
I'd like to thank the committee for providing this opportunity for the Northern Air Transport Association, or NATA, to present before it. As you've heard, my name is Stephen Nourse, and I'm the executive director of NATA. I will apologize ahead of time if my voice cracks partway through. It's allergies, perhaps, or a cold; I don't know what is still around.
NATA has approximately 107 members and represents 37 commercial air carriers, all of which operate in the northern and remote regions of Canada. We have operator members in every province and territory in Canada with the exception of the three Maritime provinces of Nova Scotia, P.E.I., and New Brunswick. None of them are particularly northern or remote, so why would we?
Our carriers run the gamut from large jet carriers like Air North, Yukon's Airline; Canadian North; First Air; and Air Inuit; all the way down to small mom-and-pop operations and everything in between. We have both fixed- and rotary-wing operators among our members.
I will begin with some comments on the transportation of dangerous goods. On a per-flight basis, I would suggest to you that NATA carriers probably carry far more dangerous goods than the major carriers do in Canada. This is simply a function of where and who our carriers service. A huge part of their market is serving northern and remote communities, where air is the only year-round access to the community. In many cases, it's the only access—period.
With no other mode to move dangerous goods, people have to ship them by air despite all the restrictions in place. Fortunately, the transportation of dangerous goods by air in Canada is a well-developed and mature system based on international standards. If there's any criticism to be made of the system, it's perhaps that in remote locations it can be a bit onerous on the shipper's part.
Air carriers have sophisticated training programs on dangerous goods for handlers, cargo agents, receivers, maintenance personnel, flight crew, even the dispatchers. The manual specifying what can fly under what circumstances, and how packaged, puts the old standby of the Toronto Yellow Pages book to shame in its size. It literally is a multi-day course just to learn how to use the manual properly.
The vast majority of businesses supplying these remote locations know the rules, know how the paperwork goes, and have the specialized labels and packaging necessary to comply with the regulations. However, along comes Fred in a remote community, and all he wants to do is bring back a new battery for his ATV. Daunted by everything involved, or simply not knowing, it ends up either in his luggage or shipped undeclared, and likely improperly packaged. Now we have a potential problem. Fortunately that's relatively rare, but nevertheless it's a potential problem.
A lot of effort is put into DG awareness to prevent this from happening, but more is needed. There also needs to be some thought on how the system could perhaps be simplified for common items moved frequently in remote communities—items such as batteries, bear bangers, snowmobiles, and ATVs, which you and I just go to the hardware store for without a single thought as to how it actually got to the store.
Moving on to safety management systems, CAR 705 operators in Canada, those operating large commercial aircraft, have been under an SMS regimen for many years now. Initially there was a lot of angst among them regarding its implementation. The angst seemed justified for a while, as at first Transport Canada did not do a good job bringing it in.
Initially there was a lot of contradictory information, resistance from the inspectors themselves, and unfortunately a very narrow view of SMS from Transport Canada, limited to just what was regulated by them. The reality is that a successful SMS program requires a cultural shift by the entire organization, not just the portions regulated by Transport.
However, if you go to any of the 705 operators today and ask them about SMS, you will find that they all support it. Yes, it adds costs and complexity to their operations. No, it has not reduced oversight despite public opinion fuelled partially by inspectors who are worried about their jobs. If anything, it has actually provided the inspectors with more and better tools to monitor carriers while still retaining all of their traditional ones.
However, even with all the perceived downsides, it nevertheless has improved the way carriers do business. It has improved safety, streamlined processes, enhanced quality, reduced costs, and above all provided a proactive focus on identifying and managing risk. Has it eliminated crashes? That's hard to say. Has it reduced risk in operations? Yes. Has it made for safer workplaces? Yes. Is it worthwhile? Absolutely yes.
What about extending it to the smaller CARs 704, 703, and 702 carriers? Well, that depends primarily on where Transport Canada is right now in its thinking process. If it is to impose exactly the same requirements the 705 carriers are subject to, then no. That would cripple many of the smaller carriers. It's not that SMS principles won't work for smaller carriers; it's just that the systems imposed on the larger carriers need to be scaled to the size and complexity of the smaller ones. A small business in which people may wear multiple hats cannot afford a dedicated SMS individual, let alone, in some cases, an entire team.
We see this in the airport world today, where the SMS burden imposed on a small certified aircraft receiving a scheduled service of less than one flight per day is simply out of proportion to the size of the actual operation.
To sum up, NATA supports and endorses safety management systems and considers them an important element in the overall aviation safety oversight program. However, they're only successful if the requirements are appropriately tailored to the size and complexity of the operation such that they are not a burden and the organization can truly embrace them as a positive.
Thank you for your attention. I'd be pleased to respond to any questions you might have afterwards.
