Part of the problem from the very beginning has been that Transport Canada will not tell you how to do SMS. They will tell you what their expectations are, but they will not tell you how to do it. That has spawned a whole industry out there of people, with the ATAC product, or the CCAA product, or from DTI, who will come in and do that for you, because Transport won't tell you.
Transport won't even tell you what your problem is. If they come in during a validation inspection, they'll say “No, that's not acceptable”, and then you have to go back and figure out what's not acceptable and how to fix it.